We have translated 6 more CRA interpretations

13 July 2026 - 11:56pm
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We have translated a CRA interpretation released last week and a further 5 CRA interpretations released in March of 1999. Their descriptors and links appear below.

These are additions to our set of 3,612 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 27 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
2026-07-08 2 April 2026 External T.I. 2025-1085691E5 F - Application of section 74.4 to an indirect transfer or loan Income Tax Act - Section 74.4 - Subsection 74.4(2) - Paragraph 74.4(2)(e) the s. 74.4(2)(e) deduction for interest/ dividends received applied where an individual made a B2B loan or pref investment via his corp to his wife’s corp
Income Tax Act - Section 74.4 - Subsection 74.4(2) no application where NIB intercorporate loan out of equity
1999-03-19 8 March 1999 External T.I. 9816785 F - DÉPENSE D'EXPLOITATION OU EN CAPITAL Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Current expense vs. capital acquisition costs of smart cards used for customers to collect loyalty points were currently deductible
19 February 1999 External T.I. 9821205 F - FRAIS DE DÉPLACEMENT Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h) travel expenses to attend board meetings were non-deductible
11 March 1999 External T.I. 9902355 F - GAIN DE JEU - GÉNÉRAL General Concepts - Audit, Filing and Assessment Procedure not the Department’s role to exhaustively study a particular project for tax planning or tax return purposes
3 March 1999 External T.I. 9902535 F - RÉGIME DE RETRAITE AMÉRICAIN 403(B) Income Tax Act - Section 248 - Subsection 248(1) - Employee Benefit Plan 403(b) pension plan is an EBP taxed the same as a 401(k) plan
5 March 1999 External T.I. 9904085 F - 8(1)A) DÉDUCTION POUR VOLONTAIRES Income Tax Act - Section 81 - Subsection 81(4) municipal employees assigned to special duties in response to an ice storm were not “volunteers”