We have translated 5 more CRA interpretations

We have translated a further 5 CRA interpretations released in April of 1999. Their descriptors and links appear below.

These are additions to our set of 3,600 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
1999-04-16 19 October 1998 Internal T.I. 9809597 F - PRÊT À L'HABITATION - 15(2.4) Income Tax Act - Section 15 - Subsection 15(2.4) - Paragraph 15(2.4)(e) home purchase loan made only to a related employee (who also was VP) likely was received qua shareholder
22 February 1999 Internal T.I. 9832477 F - INTERPRETATION 18(2) Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose property taxes on vacant land acquired for aborted expansion plans satisfied s. 18(1)(a)
Income Tax Act - Section 18 - Subsection 18(2) vacant land acquired for aborted expansion plans was held for an income-producing purpose
1999-04-02 25 March 1999 External T.I. 9806475 F - ACCESSING SURPLUS AS ALLOWED BY S. 84.1 Income Tax Act - Section 84.1 - Subsection 84.1(1) - Paragraph 84.1(1)(a) compliance with s. 84.1(1)(a) and (b) numerical limits suggested GAAR compliance
22 March 1999 External T.I. 9905465 F - MONTANT FORFAITAIRE D'UN RPA Income Tax Act - Section 104 - Subsection 104(27) RPP amount received by estate and paid out to a non-listed beneficiary loses its character as pension income
Income Tax Act - Section 108 - Subsection 108(5) - Paragraph 108(5)(a) payment sourced from RPP is property income when distributed by estate if s. 104(27) does not apply
8 April 1999 External T.I. 9909305 F - CONTENU ÉTRANGER- REER Income Tax Regulations - Regulation 5100 - Subsection 5100(2) FSTQ shares qualify as small business securities