We have translated 9 more CRA severed letters
21 September 2026 - 12:01am
Email this ContentWe have translated two recently released CRA rulings and a further 7 CRA interpretations released in January of 1999. Their descriptors and links appear below.
These are additions to our set of 3,659 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 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 |
|---|---|---|---|
| 2026-09-09 | 2026 Ruling 2025-1084051R3 F - Post-mortem pipeline | Income Tax Act - Section 84 - Subsection 84(2) | simple post-mortem pipeline |
| 2026-05-16 | 2024 Ruling 2024-1031041R3 F - Hybrid Post-mortem Pipeline | Income Tax Act - Section 84 - Subsection 84(2) | classic pipeline with slow note repayment schedule |
| 1999-01-22 | 27 October 1998 Internal T.I. 9817606 F - CIPCMC - BIEN AMORTISSABLE ET BFT | Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property | ability under IT-283, para. 8 for a producer to treat film inventory as depreciable property does not apply to videotape production or permit depreciable property to be treated as inventory |
| Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits | videotape of comedy generating a CFVP credit potentially might also qualify as goods (tangible property) for sale or lease | ||
| Income Tax Act - Section 125.4 - Subsection 125.4(3) | videotape potentially could generate both a CFVP and M&P credit | ||
| 17 December 1998 Internal T.I. 9827967 F - AVANTAGES - FONDS SOCIAL POUR EMPLOYÉS | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | social fund created out of 5/12 reduction in an employer’s employment insurance contributions would not generate taxable benefits if specifically exempted under ss. 6(1)(a)(i) to (v) | |
| 15 December 1998 Internal T.I. 9828187 F - ASSURANCE-VIE -CHANGEMENT DE BÉNÉFICIAIRE | Income Tax Act - Section 148 - Subsection 148(9) - Disposition | disposition where interest in life insurance policy acquired for cash and assumption of premium obligation | |
| Income Tax Act - Section 148 - Subsection 148(1) | company whose business is factoring life policies does not enjoy the s. 148(1) exemption | ||
| 1999-01-08 | 17 December 1998 External T.I. 9810105 F - PERTE AU TITRE D'UN PLACEMENT D'ENTREPRISE | Income Tax Act - Section 50 - Subsection 50(1) - Paragraph 50(1)(a) | s. 50(1)(a) loss cannot be recognized where the debt was settled during the year |
| Income Tax Act - Section 54 - Superficial Loss | no disposition of property to a person when debt was settled | ||
| Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) - Subparagraph 39(1)(c)(i) | s. 39(1)(c)(i) BIL cannot be recognized where the debt was settled during the year | ||
| 17 December 1998 External T.I. 9829565 F - ÉMISSION D'ACTION - 4900(12) | Income Tax Regulations - Regulation 4900 - Subsection 4900(12) | at the time of acquisition referenced immediately before rather than immediately after the acquisition | |
| Income Tax Regulations - Regulation 4900 - Subsection 4900(6) | “at the time the property was acquired” referenced the state of affairs before giving effect to the acquisition | ||
| 18 December 1998 External T.I. 9803745 F - ALLOCATION DE FIN DE CARRIÈRE - IMPOSITION | Income Tax Regulations - Regulation 2601 - Subsection 2601(1) | end-of-career allowance received by an ex-Quebec GP resident in Ontario did not have a nexus to a Quebec PE | |
| Income Tax Act - Section 248 - Subsection 248(1) - Business | end-of-career allowance received by an ex-Quebec GP was s. 12(1)(x) business income but not income from carrying on a business | ||
| 17 December 1998 External T.I. 9810095 F - ACTIONS ADMISSIBLES DE PETITE ENTREPRISE | Income Tax Act - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share - Paragraph (c) - Subparagraph (c)(i) | rental income from an Opco held by an unrelated individual but subject to a call option could be from an active business for QSBCS - (c)(i) purposes |