We have translated 6 more CRA interpretations

19 January 2026 - 11:29pm
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We have translated a further 6 CRA interpretations released in December of 1999. Their descriptors and links appear below.

These are additions to our set of 3,448 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 26 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
1999-12-10 4 June 1999 Internal T.I. 9913100 F - APPLICATION 40(2)G)(II), 20(1)C) ET 18(1)A) Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose s. 18(1)(a) can deny an expense not incurred in an activity with a reasonable expectation of profit even where s. 12 specifically requires inclusion of the smaller gross income
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) s. 12 requires the recognition of income even where the associated expenses were not incurred for profit
4 June 1999 Internal T.I. 9913120 F - APPLICATION DE 20(1)F) Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) redemption proceeds of stock option were deductible under s. 20(1)(f)
29 June 1999 Internal T.I. 9913180 F - AFFACTURAGE Income Tax Act - Section 9 - Capital Gain vs. Profit - Debt/ receivables sale of trade receivables to securitization vehicle generally on income account
24 June 1999 Internal T.I. 9913420 F - BFT- HONORAIRE DE GESTION Income Tax Regulations - Regulation 5202 - Cost of Labour cost of labour included only the salary component of managementco fees
24 June 1999 Internal T.I. 9913480 F - BIA REGROUPEMENT D'ENTREPRISE Income Tax Regulations - Schedules - Schedule II - Class 14.1 fees incurred in acquiring a similar business may be eligible capital expenditures
5 November 1999 External T.I. 9830055 F - DIVIDENDE EN ACTIONS Income Tax Act - Section 74.4 - Subsection 74.4(2) - Paragraph 74.4(2)(f) amount of stock dividend for s. 74.4(4)(f) purposes is the PUC increase