We have translated 7 more CRA interpretations

22 April 2025 - 10:15am
Email this ContentEmail this Content

We have translated a CRA interpretation released last week and a further 6 CRA interpretations released in September of 2000. Their descriptors and links appear below.

These are additions to our set of 3,174 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 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
2025-04-16 4 March 2025 External T.I. 2024-1009691E5 F - Bump and Qualifying Exchange Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c) a s. 132.2 exchange of MFC shares for MFT units precluded a s. 88(1)(d) bump of the MFT units
2000-09-15 7 September 2000 External T.I. 2000-0015905 F - allocation pour repas Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii) allowance is reasonable if it is determined on the basis of an estimate of the average costs incurred by employees on a regular basis
7 September 2000 External T.I. 2000-0017015 F - CALCUL DE LA SURTAXE Income Tax Act - Section 180.1 - Subsection 180.1(2) surtax computed on the higher of the Division E and E.1 amounts, both computed before deduction of the foreign tax credit and overseas employment tax credit
7 September 2000 External T.I. 2000-0018585 F - FRAIS DE STAGE COOPERATIF Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(a) co-op placement fees were not tuition
8 September 2000 External T.I. 2000-0023475 F - INDIEN EMPLOYE MIN AFFAIRS INDIENNES Other Legislation/Constitution - Federal - Indian Act - Section 87 earnings of a status Indian employed off-reserve by the Department of Indian and Northern Affairs were not exempted
13 September 2000 Internal T.I. 2000-0027557 F - REER AU PROFIT DU CONJOINT Income Tax Act - Section 146 - Subsection 146(1) - Spousal or Common-Law Partner Plan - Paragraph (a) - Subparagraph (a)(ii) no extension of the rule to a transfer from spousal plan via an RPP to the taxpayer’s RRSP, but GAAR might apply
31 August 2000 Internal T.I. 2000-0038757 F - ALLOCATIONS POUR FRAIS DE DEMENAGEMENT Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) first $650 of formula moving allowance (e.g., 2 weeks’ salary) was to be excluded from employment income