We have translated 6 more CRA interpretations

We have translated a further 6 CRA interpretations released in January of 2000. Their descriptors and links appear below. These are additions to our set of 3,348 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
2000-01-21 4 October 1999 Internal T.I. 9909897 F - MONTANT PENSION DIMINUE TEMPORAIREMENT Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day increased amount was not pursuant to a consent judgment since its dollar quantum was not specified
4 November 1999 Internal T.I. 9912267 F - TRANSFERT CREDIT FRAIS DE SCOLARITÉ Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(b) non-resident student who is not a Canadian taxpayer does not generate tuition tax credits
Income Tax Act - Section 248 - Subsection 248(1) - Taxpayer a taxpayer must be subject to assessment under Part I before being considered for the purposes of an ITA provision
11 October 1999 Internal T.I. 9913907 F - COURTIERS D'ASSURANCE-VIE COMMISSIONS Income Tax Act - Section 3 - Paragraph 3(a) commission of self-employed sales rep in acquiring insurance for personal coverage is not business income
12 January 2000 Internal T.I. 9918467 F - CORRECTION PARTAGE VS. SOULTE
s. 12(1)(x)(iv) application confirmed in 2000-0046180 F

Income Tax Act - Section 248 - Subsection 248(20) post-partition assumption by one party of the other’s mortgage was intended to correct an error in the delineation of each’s 50-50 share, and did not entail a disposition
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(iv) compensation for excess mortgage payments (including principal amortization) previously made on partitioned property was s. 12(1)(x)(iv) income
16 December 1999 Internal T.I. 9919007 F - PENSION ALIMENTAIRE DATE D'EXECUTION Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day pre-transition day agreement continued to govern the support amounts (no commencement day)
1 December 1999 Internal T.I. 9919237 F - RENTE VIAGERE-PENSION ALIMENTAIRE Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount lump sum support obligation that was required to be satisfied through the purchase of an annuity did not constitute periodic support