We have translated 6 more CRA severed letters
30 March 2026 - 11:19pm
Email this ContentWe have translated a CRA ruling released two weeks ago and a further 5 CRA interpretations released in July of 1999. Their descriptors and links appear below.
These are additions to our set of 3,519 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 26 ½ years of releases of such items by the Directorate. These translations are subject to our paywall (applicable after the 5th of each month).
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2026-03-18 | 2025 Ruling 2025-1054291R3 - Post-Mortem Hybrid Pipeline | Income Tax Act - Section 84 - Subsection 84(2) | hybrid double pipeline with a choice between amalgamating or winding up |
| 1999-07-23 | 7 July 1999 External T.I. 9828165 F - TRANSFERT DE BIENS À UNE SOCIÉTÉ | Income Tax Act - Section 74.4 - Subsection 74.4(2) | taking back non-cumulative preferred shares may be indicative of a targeted main purpose |
| 30 June 1999 External T.I. 9911555 F - CR POUR ACTIONNAIRE-DIRIGEANT | Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement | foregoing by a shareholder-officer of significant salary in exchange for an RCA contribution, may be an SDA | |
| 1999-07-09 | 24 June 1999 External T.I. 9830665 F - DIVIDENDE EN ACTIONS PRIV ET PAR BILLET
quoted in 2011-0415891E5 F (translated), reversed by 2018-0780071C6
|
Income Tax Act - Section 248 - Subsection 248(28) | double taxation of s. 55(2) gain on dividend in kind avoided by excluding gain on subsequent sale of the dividended property |
| Income Tax Act - Section 52 - Subsection 52(1) | cost of note increased only by the taxable capital gain recognized under s. 55(2) in respect of its issuance as a dividend in kind | ||
| Income Tax Act - Section 52 - Subsection 52(3) - Paragraph 52(3)(a.1) | nil cost of preferred shares issued on dividend in kind by virtue of s. 52(3)(a.1) since deemed not to be a dividend by s. 55(2) | ||
| 28 June 1999 External T.I. 9912585 F - ALLOCATION DE RETRAITE | Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | whether transfer between two companies entails termination of employment turns on whether they are affiliated/ ordinary meaning of affiliated | |
| 30 June 1999 External T.I. 9912605 F - APPLICATION DE 56(11) À L'EMPLOYEUR | Income Tax Act - Section 56 - Subsection 56(11) | the recipient of the amount subject to s. 56(11) need not have held the employment, so that it could apply to an employer |