We have translated 9 more CRA interpretations

1 September 2026 - 11:41pm
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We have translated a CRA interpretation released last week and a further 8 CRA interpretations released in February and January of 1999. Their descriptors and links appear below.

These are additions to our set of 3,650 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
2026-08-26 1 April 2026 Internal T.I. 2025-1050651I7 F - Application du paragraphe 50(1) LIR - Choix relatif aux créances devenues irrécouvrables Income Tax Act - Section 50 - Subsection 50(1) s. 50(1) elections must be made on a debt-by-debt basis
1999-02-05 11 January 1999 Internal T.I. 9820337 F - SOCIÉTÉS ASSOCIÉES
discussed in 2001-0092035 F

 Income Tax Act - Section 256 - Subsection 256(1.4) - Paragraph 256(1.4)(a) right of equal shareholders to acquire additional shares in the same number did not deem either to control the corporation
14 January 1999 Internal T.I. 9821980 F - IS THERE A BUSINESS FOR THE PURPOSE OF S. 17? Income Tax Act - Section 17 - Subsection 17(3) use of lent money to acquire condo for rental to indirect shareholder and, then, 3 terms deposits, did not satisfy s. 17(3) income-producing use test
14 January 1998 External T.I. 9829915 F - PARA. 5 SEC. 29 CANADA-FRANCE TAX TREATY Treaties - Income Tax Conventions - Article 29 cross-border pension contribution rule in Art. 29(5) of the Canada-France Convention could be satisfied even where the contribution was not made in the same year as the services rendered
1999-01-22 17 December 1998 Internal T.I. 9822637 F - PRESTATIONS D'INVALIDITÉ Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) tainting effect of employer contributions can come from predecessor plan
18 January 1999 Internal T.I. 9828227 F - RACHAT D'OPTIONS D'ACHAT D'ACTIONS Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) payment made to redeem a share purchase option was deductible as to ¾ under s. 20(1)(f)(ii)
22 December 1998 Internal T.I. 9830297 F - CONJOINT Income Tax Act - Section 248 - Subsection 248(1) - Common-Law Partner individual may have two spouses
6 January 1999 External T.I. 9832505 F - ACT. PRIV. IMPOSABLE TAXABLE PREFERRED SHARE Income Tax Act - Section 191 - Subsection 191(4) - Paragraph 191(4)(d) - Subparagraph 191(4)(d)(i) s. 191(4)(d)(i) does not apply to the redemption of a TxPS issued in exchange for a TxPS that, in turn, was issued in exchange for a non-TxPS
5 January 1999 External T.I. 9833535 F - PENSION GRC Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(i) pensions received under non-enumerated provisions are not exempted