We have translated 7 more CRA interpretations

5 August 2025 - 11:44pm
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We have translated a CRA interpretation released last week and a further 6 CRA interpretations released in May and April of 2000. Their descriptors and links appear below.

These are additions to our set of 3,276 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 25 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
2025-07-30 1 May 2025 External T.I. 2024-1030911E5 F - Scholarships to non-residents to study French Income Tax Act - Section 118.94 scholarships received by non-resident temporary workers for French language training would be included in their worldwide income s. 118.94 computation purposes
Income Tax Act - Section 115 - Subsection 115(2) - Paragraph 115(2)(e) - Subparagraph 115(2)(e)(ii) scholarships received by non-resident temporary workers for French language training would not be included in their taxable income earned in Canada
2000-05-12 5 April 2000 Internal T.I. 2000-0009467 F - EQUIV. DU MONTANT POUR CONJOINT Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) taxpayer could not claim the s. 118(1)(b) credit for a child in the year of separation for whom he did not have custody
2000-04-28 13 April 2000 External T.I. 2000-0006635 F - CONJOINT DE FAIT DE MEME SEXE Income Tax Act - Section 146.01 - Subsection 146.01(1) - HBP Balance new common-law partner provisions did not extend to HBPs
7 April 2000 External T.I. 2000-0016275 F - Spin-off to individual shareholders Income Tax Act - Section 90 - Subsection 90(1) treatment of foreign spin-off as s. 90(1) dividend
19 April 2000 External T.I. 1999-0010095 F - Income earned or realized - capital loss Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) safe income of public corporation reduced by full amount of capital loss
14 April 2000 External T.I. 1999-0013795 F - RESIDENCE PRINCIPALE Income Tax Act - Section 40 - Subsection 40(4) - Paragraph 40(4)(a) transferee spouse could designate the cottage as her principal residence
13 April 2000 External T.I. 1999-0014465 F - UTILISATION DE PRODUITS D'ASSURANCE-VIE Income Tax Act - Section 74.1 - Subsection 74.1(1) insurance policy generates property income, so that s. 74.1 attribution rules could apply
Income Tax Act - Section 148 - Subsection 148(9) - Disposition - Paragraph (d) addition of disability option clause to an insurance policy results in its disposition by operation of law if under the CCQ such change “results in the creation of a new contract”