We have translated 6 more CRA severed letters

1 June 2026 - 10:55pm
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We have translated a further CRA ruling released last week and 5 CRA interpretations released in April of 1999. Their descriptors and links appear below.

These are additions to our set of 3,580 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 27 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
2026-05-27 2025 Ruling 2024-1036051R3 F - Trust to trust transfer and vested indefeasibly Income Tax Act - Section 108 - Subsection 108(1) - Trust - Paragraph (g) trust-to-trust transfer to permit indefeasible vesting before the 21st anniversary
Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (f) no disposition on trust-to-trust transfer with 2nd trust permitting indefeasible vesting
1999-04-30 20 April 1999 External T.I. 9824625 F - FRAIS DE SCOLARITÉ Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(a) tuition refund received 3 years later requires amendment of initial return
19 April 1999 External T.I. 9900675 F - DÉCRET DE REMISE- TEMPÊTE VERGLAS Income Tax Act - Section 5 - Subsection 5(1) humanitarian monetary assistance of employer to employees was taxable
21 April 1999 External T.I. 9902395 F - FRAIS ORDINATEUR FOURNI PAR ÉTABLISSEMENT Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(a) computer use fees qualified as tuition
19 April 1999 External T.I. 9909875 F - OSBL- CAPITAL VERSÉ RETOURNÉ Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) right of shareholder to receive PUC on wind-up does not by itself disqualify
20 April 1999 Internal T.I. 9910097 F - CONTENU ÉTRANGER - REER Income Tax Act - Section 39 - Subsection 39(5) FTQ shares qualify for exclusion as a prescribed labour-sponsored venture capital corp.