We have translated 6 more CRA interpretations

10 February 2025 - 11:38pm
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We have translated a further 6 CRA interpretations released in February of 2001. Their descriptors and links appear below.

These are additions to our set of 3,103 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 24 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
2001-02-02 7 December 2000 Internal T.I. 2000-0023207 F - OPTIONS D'ACHAT D'ACTIONS Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) s. 7(3)(b) does not preclude employer from deducting amounts paid out under stock option agreement
18 December 2000 Internal T.I. 2000-0023807 F - IMPORT DE LA PARTIE 1.3 COMPENSATION Income Tax Act - Section 181 - Subsection 181(3) loan set-off in accordance with GAAP reduced the taxpayer’s capital
8 November 2000 Internal T.I. 2000-0025167 F - RECONNAISSANCE DU REVENU D'INTERET Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) interest paid to the taxpayer on cancelling an assessment was income to the subrogated insurer
General Concepts - Ownership interest on tax refund was income to the insurer who had been subrogated to the taxpayer’s claim against CRA
15 January 2001 External T.I. 2000-0033765 F - DEDUCTION DES INTERETS/RACHATS D'ACTIONS Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) policy re loans to distribute PUC or accumulated profits, or redeem
1 December 2000 Internal T.I. 2000-0048437 F - PAIEMENTS ANTERIEURS Income Tax Act - Section 56.1 - Subsection 56.1(3) agreement must show a clear intent to amend the agreement to include the prior payments
19 January 2001 Internal T.I. 2000-0049187 F - PENSION ALIMENTAIRE-ACCORD SUBSEQUENT Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day - Paragraph (b) - Subparagraph (b)(iii) amendment to support amount triggered a commencement day