We have translated 6 more CRA interpretations

We have translated a further 6 CRA interpretations released in December and November of 1999. Their descriptors and links appear below.

These are additions to our set of 3,465 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 5 November 1999 External T.I. 9901555 F - SOCIETE EXPLOITANT UNE PETITE ENTREPRISE Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation shareholding held by taxpayer was not necessary for the operation of its business
1999-11-26 20 October 1999 External T.I. 9904125 F - TRANSFORMATION D'ARTICLES DESTINÉS À LA VENTE Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits subcontractor’s manufacturing of parts out of materials owned by the car manufacturer could qualify
25 October 1999 External T.I. 9908775 F - RESIDENCE-ACTIF ADMISSIBLE Income Tax Act - Section 110.6 - Subsection 110.6(1) - Interest in a Family Farm or Fishing Partnership - Paragraph (a) - Subparagraph (a)(i) farming partnership residence for on-call partners is used in the farming business
25 October 1999 External T.I. 9910355 F - TRANSFORMATION D'ARTICLES DESTINÉS À LA VENTE Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits subcontractor to goods vendor doing processing of such goods can qualify
25 May 1999 Income Tax Severed Letter 9913410 F - VALEUR DÙN CAAF Income Tax Act - Section 68 where saw mill sold and timber supply agreement relinquished, s. 68(1) could apply to allocate a portion of such proceeds to such agreement
29 August 1999 Income Tax Severed Letter 9923446 F - ACTIONS ACCRÉDITIVES-MODIFICATION DU PBR Income Tax Act - Section 66.3 - Subsection 66.3(3) flow-through shares have deemed nil cost even if CEE deduction subsequently denied