We have translated 6 more CRA interpretations

5 May 2025 - 11:40pm
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We have translated a further 6 CRA interpretations released in September and August of 2000. Their descriptors and links appear below.

These are additions to our set of 3,188 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
2000-09-01 18 May 2000 Internal T.I. 2000-0006037 F - FRAIS D'ACQUISITION Income Tax Act - Section 9 - Timing commissions directly related to the acquisition of a life insurance policy are generally deductible in the year incurred
Income Tax Act - Section 18 - Subsection 18(9.02) limited scope of proposed s. 18(9.02)
24 August 2000 Internal T.I. 2000-0034117 F - PROGRAMME DE RETRAITE ANTICIPÉE Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance amounts treated by employer as remuneration for CPP and EI purposes generally will not be retiring allowances
8 June 2000 Internal T.I. 1999-0012817 F - Sociétés associées Income Tax Act - Section 256 - Subsection 256(6) s. 256(6)(b) was not satisfied because control also held to protect investment in building and because shares were to be purchased for cancellation rather than redeemed
Income Tax Act - Section 256 - Subsection 256(3) s. 256(3) does not apply where s. 256(6) does not apply
2000-08-18 31 July 2000 External T.I. 2000-0015925 F - ASSURANCE COLLECTIVE MALADIE ACCIDENTS Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) group sickness or accident insurance plan cannot be based in part on loss of corporate retained earnings
31 July 2000 Internal T.I. 2000-0017597 F - COMMISSION-POLICES D'ASSURANCE-VIE Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit commissions of a life insurance salesperson on acquiring an annuity contract or segregated fund policy are not exempted under IT-470R, para. 27
31 July 2000 External T.I. 2000-0022555 F - FRAIS DE DÉMÉNAGEMENT-RÉS. TEMPORAIRE Income Tax Act - Section 248 - Subsection 248(1) - Eligible Relocation temporary new residence ignored if shift of ordinary residence is to permanent residence