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These are additions to our set of 3,083 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 23 ¾ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2025-02-12 11 December 2024 External T.I. 2024-1039101E5 F- Vertical amalgamation & former paragraph 84.1(2)(e) Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(e) s. 87(2)(j.6) continuity rule does not remediate the adverse consequences under the old intergenerational transfer rules of vertically amalgamating the subject corp Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(j.6) s. 87(2)(j.6) does not apply for purposes of the “old” s. 84.1(2)(e) intergenerational transfer rules 2001-02-02 23 October 2000 Internal T.I. 2000-0027477 F- ALLOCATION DE RETRAITE Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance exclusion for replacement employment at an alleged affiliated employer was not applied 2001-01-19 5 January 2001 External T.I. 2000-0010905 F- Valuation- Freeze shares General Concepts- Fair Market Value- Shares requirement to seek consent detracts to retraction detracts from FMV of freeze preferred shares Income Tax Act- Section 86- Subsection 86(1) right to retract freeze preferred shares must not be fettered 4 January 2001 External T.I. 2000-0047605 F- FRAIS DE DIVERTISSEMENT Income Tax Act- Section 67.1- Subsection 67.1(1) attending shows in order to identity artist recruits might be entertainment Income Tax Act- Section 67.1- Subsection 67.1(2)- Paragraph 67.1(2)(a) s. 67.1(2)(a) exception unavailable for tickets to shows attended to recruit artists 10 January 2001 External T.I. 2000-0049585 F- DEDUCTIBILITE DES INTERETS Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) annual payment cap on interest until maturity did not preclude deductibility 5 January 2001 Internal T.I. 2000-0053767 F- IT-92R2 Paragraphe 1 Income Tax Act- Section 9- Timing progress method per IT-92R2 could be used by supplier of kitchen equipment if installed by it pursuant to the building construction plans and title thereto thereupon vested in the building owner Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(b) construction holdbacks not receivable until approved for release 2001-01-05 19 December 2000 External T.I. 2000-0035685 F- RPA TRANSFER AU DECES Income Tax Act- Section 147.3- Subsection 147.3(7) deceased member can have had more than one qualifying spouse or partner ...

These are additions to our set of 3,129 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 ¼ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2000-11-24 3 November 2000 External T.I. 2000-0047535 F- CHNT USAGE-UN IMMEUBLE Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(a) building of the taxpayer with 4 units treated as 4 separate properties for purposes of the change-in-use rules Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(b)- Subparagraph 13(7)(b)(ii)- Clause 13(7)(b)(ii)(B) change in use of unit in 4-plex from personal to rental and vice versa 31 October 2000 Internal T.I. 2000-0048427 F- PENSION ALIMENTAIRE-ARRERAGES Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount amount of support can be payable under a court order although the amount paid is less 10 November 2000 External T.I. 1999-0008335 F- inclusion revenu exonéré- convention fiscale Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(a) requirement to include a treaty-exempt receipt in income 9 November 2000 External T.I. 2000-0038955 F- CLAUSE DE CAPACITE DE GAIN Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) ascertaining 5-year earnout period / meaning of “calculated with certainty” 7 November 2000 External T.I. 2000-0040615 F- OPTIONS ET CLAUSE DE CAPACITE DE GAIN Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) IT-426 cost-recovery method not available where earnout is embedded in the variable proceeds received for the granting of a share-sale option with nominal exercise price Income Tax Act- Section 49- Subsection 49(1) granting of earnout option may require full recognition under s. 49(1) on grant date/ legal form of option v. share sale generally followed 7 November 2000 External T.I. 2000-0041815 F- ALLOC. ...

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 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 are additions to our set of 3,195 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 are additions to our set of 3,209 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 are additions to our set of 3,221 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. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2025-07-02 29 April 2025 External T.I. 2024-1036641E5 F- Relevant Group Entity Income Tax Act- Section 84.1- Subsection 84.1(2.31)- Paragraph 84.1(2.31)(c)- Subparagraph 84.1(2.31)(c)(iii) a Realtyco, whose shares qualified as QSBCS based on a related corporation’s active business, would be a “relevant group entity” on a sale of the latter’s shares Income Tax Act- Section 84.1- Subsection 84.1(2.32)- Paragraph 84.1(2.32)(c)- Subparagraph 84.1(2.32)(c)(iii) continued control of the related lessor to an Opco would violate the s. 84.1(2.32)(c)(iii) condition on a sale of Opco to a child’s purchaser corporation 2000-06-23 10 May 2000 Internal T.I. 2000-0016257 F- RPA COTISATIONS POUR SERVICES ANTERIEURS Income Tax Act- Section 147.2- Subsection 147.2(4)- Paragraph 147.2(4)(c) no retroactive deduction 19 May 2000 Internal T.I. 2000-0018477 F- DEDUCTION A LA SOURCE Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(j) amounts paid out of RRSP to trustee in bankruptcy pursuant to judgment were subject to source deductions even though no mention thereof in court order 2000-06-09 8 June 2000 External T.I. 1999-0006105 F- TRANSFERT DE BIENS A UN CONJOINT Income Tax Act- Section 74.1- Subsection 74.1(1) CCRA has not yet developed a position re where the transferred property itself is returned to the transferor spouse in repayment of the transferee spouse’s debt 15 May 2000 Income Tax Severed Letter 2000-0008210 F- ADMINISTRATEUR DE FACTO Income Tax Act- Section 227.1- Subsection 227.1(1) individual can be a de facto director who acts as such with the shareholders’ agreement or takes significant actions with 3rd parties in the corporation’s name 31 May 2000 External T.I. 2000-0009695 F- FRAIS MEDICAUX-PREPOSE A PLEIN TEMPS Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(b) meaning of “one full-time attendant … for the full-time care of the individual” 5 June 2000 External T.I. 2000-0010615 F- Developpement d'un equipement- RS&DE Income Tax Act- Section 37- Subsection 37(8)- Paragraph 37(8)(d) expenditures to develop SR&ED equipment could be current expenses ...