We have translated 10 more CRA severed letters

19 August 2026 - 12:35am
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We have translated a CRA interpretation and ruling released last week and a further 8 CRA interpretations released in February of 1999. Their descriptors and links appear below.

These are additions to our set of 3,641 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 ½ 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
2026-08-12 2024 Ruling 2024-1037251R3 F - Post-mortem planning - Pipeline Income Tax Act - Section 84 - Subsection 84(2) post-mortem pipeline where there was a change in the business of the subject corporation while in the hands of the estate
14 May 2026 External T.I. 2025-1054171E5 F - FHSA and acquisition of a "qualifying home" Income Tax Act - Section 146.6 - Subsection 146.6(1) - Annual FHSA Limit - Paragraph (c) an individual can continue contributing to an FHSA after acquiring an owner-occupied home
Income Tax Act - Section 146.01 - Subsection 146.01(1) - Maximum Participation Period Maximum Participation Period does not terminate when the taxpayer acquires an owner-occupied home
1999-02-05 27 January 1999 External T.I. 9807175 F - STAGE COOPÉRATIF - CRÉDIT ÉTUDE, FRAIS SCOL Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(a) per-credit fee charged for unpaid practical training placements qualified as tuition
21 January 1999 External T.I. 9810945 F - 74.1 - CONCEPT DE TRANSFERT Income Tax Act - Section 74.1 - Subsection 74.1(2) s. 74.1(2) applied to contributions to a trust for the benefit of minor children even though no amounts generally distributed to them while minors
26 January 1999 External T.I. 9819805 F - INDEMNITÉ Income Tax Act - Section 54 - Proceeds of Disposition gratuitous compensation paid by broker to compensate client for meager sales proceeds may constitute proceeds of disposition
18 January 1999 External T.I. 9825425 F - COMPTE DIVIDENDE EN CAPITAL Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) life insurance proceeds received by creditor which was the stated beneficiary did not add to CDA of debtor
21 January 1999 External T.I. 9829465 F - DIMINUTION LOYER CONTRE PRET SANS INTERET Income Tax Act - Section 105 - Subsection 105(1) s. 105(1) can apply to a benefit conferred on a non-beneficiary but does not apply to a barter exchange
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) tenant can deduct interest on interest-free loan made to landlord where this was a barter exchange for free rent
Income Tax Act - Section 9 - Computation of Profit barter exchange of free rent for interest-free loan
18 January 1999 External T.I. 9833975 F - REGIME D'ACCESSION PROPRIÉTÉ Income Tax Act - Section 146.01 - Subsection 146.01(1) - Regular Eligible Amount - Paragraph (f) legatee can acquire from estate if had not been an owner-occupier
30 September 1998 External T.I. 9801675 F - ÉVALUATION D'ACTIONS Income Tax Act - Section 15 - Subsection 15(1) no taxable benefit conferred on common shareholders where one of the two pref holders agrees to a reduced redemption price based on the decline in the after-tax underlying NAV
General Concepts - Fair Market Value - Shares tax attributable to rollover basis in assets is no longer considered to reduce their FMV
27 January 1999 External T.I. 9802745 F - ALLOCATIONS AUTOMOBILE- REMBOURSEMENT Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) administrative policy to permit inclusion of both fixed and reasonable variable automobile allowance in income, and deduct expenses