We have translated 6 more CRA interpretations

1 September 2025 - 11:33pm
Email this ContentEmail this Content

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

These are additions to our set of 3,303 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
2025-08-27 4 July 2025 Internal T.I. 2025-1054791I7 F - Provincial allocation - CEWS Income Tax Regulations - Regulation 402 - Subsection 402(3) CEWS is excluded from gross revenue and wages for Reg. 402(3) purposes
Income Tax Regulations - Regulation 402 - Subsection 402(3) gross revenue does not include government assistance re expenses
2000-03-31 15 February 2000 Internal T.I. 2000-0004537 F - UNDP ORGANISATION INT'LE VISEE x REGL Income Tax Act - Section 110 - Subsection 110(1) - Paragraph 110(1)(f) - Subparagraph 110(1)(f)(iii) UNDP and UNOPS were subsidiary admin bodies of the UN/ the taxpayer's income was not exempted because she was an independent contractor
7 March 2000 Internal T.I. 1999-0007497 F - AIDE A DOMICILE-PRESTATION DE L'ART SAAQ Income Tax Act - Section 3 - Paragraph 3(a) insurance-funded assistance to the mother of a severely injured child for her care services was business income to her net of her care expenses (e.g., daycare)
18 February 2000 Internal T.I. 1999-0008457 F - Life Insurance Corporation Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation - Paragraph (a) a public corporation for purposes of the CCPC definition includes a corporation deemed to be a public corporation under s. 141
Income Tax Act - Section 256 - Subsection 256(9) status of the subject corporation as controlled by a public corporation was determined immediately before the deemed s. 256(9) acquisition time
2000-03-17 2 March 2000 External T.I. 1999-0007515 F - CONTRAT DE RENTE PRESCRIT-HYPOTHEQUE Income Tax Regulations - Regulation 304 - Subsection 304(1) - Paragraph 304(1)(c) a PAC can be encumbered by a hypothec
24 February 2000 External T.I. 1999-0009925 F - T1135 - Déclarations générales Income Tax Act - Section 233.3 - Subsection 233.3(1) - Specified Foreign Property - Paragraph (a) location of corporate debt or shares generally is the place of residence of the corporation
9 November 1999 External T.I. 9906255 F - CALCUL DE L'IMPOT P. IV - 55
rev'd by 2008-0266191E5 F

 Income Tax Act - Section 186 - Subsection 186(1) - Paragraph 186(1)(b) s. 55(2) reduced the amount of the deemed dividend received for s. 186(1)(b)(i) purposes