We have translated 5 more CRA interpretations

8 June 2026 - 11:39pm
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We have translated a further 5 CRA interpretations released mostly in April of 1999. Their descriptors and links appear below.

These are additions to our set of 3,585 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
2000-06-23 15 June 2000 Internal T.I. 2000-0024427 F - PENSION ALIMENTAIRE - ALLOCATION Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount agreement to pay the daycare expenses of daughter did not constitute an allowance
Income Tax Act - Section 56.1 - Subsection 56.1(2) per Pelchat, a simple reference to the tax consequences of the payment of certain sums might be considered as a reference to ss. 56.1(2) and 60.1(2)
1999-04-30 13 January 1999 Internal T.I. 9822747 F - EQUIVALENT DU MONTANT POUR CONJOINT Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) where joint custody, choice as to which claims the credit
5 February 1999 Internal T.I. 9826537 F - EXPRESSION CHANTIER PARTICULIER 6(6) Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) - Subparagraph 6(6)(a)(i) “special work site” is not restricted to a construction site and included an office in Belgium
1999-04-16 9 April 1999 Income Tax Severed Letter 9906056 F - FRAIS LÉGAUX/RÉGIME D'ASSURANCE-SALAIRE Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(b) legal fees incurred to recover salary insurance plan benefits were non-deductible
Income Tax Act - Section 248 - Subsection 248(1) - Employment individual was not an employee of an insurer as not it its service
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose s. 18(1)(a) applied on the basis of the main reason for which expense incurred
6 April 1999 Income Tax Severed Letter 9906196 F - REEE - SENS DE AUTRE SOUSCRIPTEUR Income Tax Act - Section 204.94 - Subsection 204.94(2) - Variable A - Paragraph (a) - Subparagraph (a)(ii) "plan under which there is no subscriber" refers to where, following the death of an individual, there is no subscriber under paras (a) and (b) of the definition of subscriber in s. 146.1