We have translated 6 more CRA interpretations

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

These are additions to our set of 3,477 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
1999-11-26 1 October 1999 Internal T.I. 9900727 F - PRESTATION DE RETRAITE VS PENSION ALIMENTAIRE Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount payment of ½ of his pension payments to his ex-spouse did not constitute support
Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) payment of ½ of his pension payments to his ex-spouse were excluded from the taxpayer’s income under s. 56(1)(a)(i)
9 September 1999 Internal T.I. 9902717 F - DÉDUCTIBILITÉ D'UN REMBOURSEMENT DE DETTE Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) claims against co-owners for their failure to pay their share on defaulted assumed mortgage were not acquired for an income-producing purpose
Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) no disposition and, therefore, no capital loss on paying under residual covenant on assumed but defaulted mortgage
16 September 1999 Internal T.I. 9913380 F - CONF. CONS. TECHNIQUES - COÙT EN CAPITAL Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(c) personal vehicle use by employee is business use by the employer, whereas personal use by shareholder is not
Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(g) apportionment of prescribed amount is required where the vehicle is used in part personally by a shareholder (employee personal use is business use)
16 September 1999 Internal T.I. 9913390 F - CONF. CONS. TECHNIQUES - REVENU NON DÉCLARÉ Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - E RC cannot treat unreported prior years as including CCA claims
19 October 1999 Internal T.I. 9922707 F - OSBL CHANGEMENT DE STATUE Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) NPO can qualify under s. 149(1)(l) even if it was originally organized for profit
6 October 1999 Internal T.I. 9925307 F - CONVENTION DE RETRAITE Income Tax Act - Section 248 - Subsection 248(1) - Retirement Compensation Arrangement general discussion