We have translated 8 more CRA severed letters

23 September 2025 - 11:45am
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We have translated a CRA ruling and interpretation released last week and a further 6 CRA interpretations released in March and February of 2000. Their descriptors and links appear below.

These are additions to our set of 3,324 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 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
2025-09-17 19 June 2025 External T.I. 2024-1045841E5 F - Application of subsection 152(4.2) of the Act at death Income Tax Act - Section 152 - Subsection 152(4.2) the heir of a deceased employee who became entitled to a tax-free pay adjustment should count the s. 152(4.2) 10-year claim period from the year of payment
Income Tax Act - Section 5 - Subsection 5(1) retroactive pay adjustment that was agreed to after the employee’s death was non-taxable
Income Tax Act - Section 3 - Paragraph 3(a) retroactive pay adjustment that arose after death was tax-free
2025 Ruling 2025-1052291R3 F - Post-mortem Hybrid Pipeline Income Tax Act - Section 84 - Subsection 84(2) post-mortem pipeline entailing issuance of 8 quarterly notes by Newco 12 months after its acquisition of the stepped-up shares
Income Tax Act - Section 89 - Subsection 89(1) - Paid-Up Capital transactions contemplated the distribution of all the PUC of common shares
2000-03-03 20 December 1999 Internal T.I. 9921307 F - GAINS DE PARIS SPORTIFS Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit net sports betting winnings were from a business
2000-02-18 3 February 2000 External T.I. 1999-9909275 F - FRAIS DE PLACEMENTS Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) pro-rating of capital cost based on investment-use portion
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management investment advisory subscription costs were capital expenditures
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose automobile expense not deductible from property income
8 December 1999 External T.I. 9924785 F - ASSOCIÉ DÉTERMINÉ Income Tax Act - Section 248 - Subsection 248(1) - Specified Member - Paragraph (a) limited partners were specified members notwithstanding that their shareholders took an active part in the partnership business
14 January 2000 Internal T.I. 9927897 F - OPERATIONS SUR MARCHE A TERME Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives speculator could change from capital treatment to income method for his commodity futures transactions
Income Tax Act - Section 261 - Subsection 261(2) - Paragraph 261(2)(b) fixed or average exchange rate could be used for the year’s US commodity futures transactions
22 December 1999 Internal T.I. 9931176 F - DÉFINITION - DÉPENSE DE MAIN D'OEUVRE Income Tax Act - Section 125.4 - Subsection 125.4(1) - Labour Expenditure chef’s salary and legal, accounting and insurance costs were not directly attributable (i.e., in immediate relation) to the specified CFVP production stages
31 January 2000 External T.I. 1999-0002695 F - SER. D'AIDE CONC. LA SANTE Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) exception for health counselling services