We have translated 7 more CRA interpretations

9 September 2025 - 12:16am
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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 3,310 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 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
2025-09-03 3 June 2025 External T.I. 2025-1064821E5 F - Related persons Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(iii) repeated application of ss. 251(2)(b)(ii) and (iii) to relate two corporations
2000-03-17 3 March 2000 Internal T.I. 2000-0002337 F - COOPERATIVES Income Tax Act - Section 137 - Subsection 137(6) - Credit Union Quebec cooperative did not qualify as a credit union in light of not being incorporated under the Credit Unions Act and not having statutory authorization to conduct business as a credit union
Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business Quebec cooperative did not qualify for the exclusion from SIB for a credit union
2000-03-03 16 February 2000 External T.I. 1999-0008435 F - Société associées Income Tax Act - Section 256 - Subsection 256(1.3) application of s. 256(1.3) was insufficient to create a control group
Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(f) - Subparagraph 256(1.2)(f)(ii) deemed holding of shares of corporation by each beneficiary of a family trust
15 February 2000 External T.I. 1999-0015155 F - SOCIETE EXPLOITANT UNE PETITE ENTRE. Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation corporation leasing its realty to a related active business CCPC could qualify
10 February 2000 External T.I. 1999-0002765 F - APPLICATION DE LA LOI Income Tax Act - Section 129 - Subsection 129(6) Norco Developments does not support treating rental income paid by one partnership to another as rent paid by a partner to itself as partner of the recipient partnership
11 February 2000 External T.I. 1999-0003275 F - AIDE FINAN. VERGLAS-ERABLIERE Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (f) inclusion under (f) of compensation for damages for destroyed maple trees except re repair expenses including consultants’ fees
Income Tax Act - Section 43 - Subsection 43(1) ACB of maple trees destroyed by ice storm determined based on relative number of taps
Income Tax Act - Section 248 - Subsection 248(1) - Property maple trees, although immovable property, were separate capital properties from the land
11 February 2000 External T.I. 1999-0003965 F - DEPENSES ENGAGEES-PROVISIONS Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense reserve for future replacement of building components not currently deductible