We have translated 6 more CRA interpretations

We have translated a further 6 CRA interpretations released in April and March of 2000. Their descriptors and links appear below.

These are additions to our set of 3,296 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 25 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
2000-04-14 29 March 2000 Internal T.I. 2000-0001367 F - PAIEMENT POUR SE LIBERER D'UNE HYPOTHEQUE Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) sum paid on the disposition of a property to be released from the contingent liability on the mortgage that was assumed by the purchaser, was non-deductible
Income Tax Act - Section 18 - Subsection 18(9.1) s. 18(9.1) did not apply to payment to be released from contingent payment obligation on assumed mortgage
2000-03-31 14 March 2000 External T.I. 1999-0007475 F - REMISE DE DETTE Income Tax Act - Section 20.1 - Subsection 20.1(1) pro rata application of s. 20.1(1)(b) where shares acquired with two loans are wholly applied to settle the first loan
22 March 2000 External T.I. 1999-0013995 F - ECHANGE D'ACTIONS Income Tax Act - Section 7 - Subsection 7(1.5) s. 7(1.5) exchange of securities is subject to capital gains treatment
Income Tax Act - Section 7 - Subsection 7(1.3) where only some of the securities exchanged are subject to s. 7, subsequent dispositions out of each pool are pro rata
24 March 2000 External T.I. 2000-0002775 F - Revenu gagné dans une province Income Tax Regulations - Regulation 402 - Subsection 402(5) interest on non-listed investments not excluded
Income Tax Regulations - Regulation 402 - Subsection 402(3) gross revenue excludes capital gains and, where from investments, is allocated based on where the investment decisions are made
23 March 2000 Internal T.I. 2000-0003277 F - INTERNE ET REP Income Tax Act - Section 146.02 - Subsection 146.02(1) - Eligible Amount - Paragraph (f) qualification of a medical intern
Income Tax Act - Section 146.02 - Subsection 146.02(1) - Repayment Period repayment period for the medical intern began at the start of the third calendar year of his participation period
20 March 2000 External T.I. 1999-0005815 F - BIEN DE REMPLACEMENT-DATE DE DISPOSITION Income Tax Act - Section 44 - Subsection 44(2) - Paragraph 44(2)(a) disposition for component of destruction where final compensation determined for that component
Income Tax Act - Section 44 - Subsection 44(5) leasehold interest can be a replacement property to building