We have translated 6 more CRA interpretations

17 November 2025 - 11:35pm
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We have translated a further 6 CRA interpretations released in January of 2000. Their descriptors and links appear below.

These are additions to our set of 3,373 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
2000-01-07 11 July 1999 External T.I. 9920950 F - INTÉRÊT SUR PRÊT PARTICIPATIF Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) interest not deductible under s. 20(1)(e)
2 September 1999 APFF Roundtable Q. 1, 9920900 F - IMMIGRANT - OPTION D'ACHAT D'ACTIONS Income Tax Act - Section 128.1 - Subsection 128.1(10) - excluded right or interest - Paragraph (c) stock option rights granted to American by US employer were excluded rights when he immigrated
Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) s. 7 applies to exercise in Canada of stock option that was granted and received outside Canada
31 August 1999 APFF Roundtable Q. 3, 9920920 F - RAPATRIEMENT DU CAPITAL D'UNE LLC Income Tax Act - Section 90 - Subsection 90(1) LLC return of subscription treated as PUC distribution
Income Tax Act - Section 90 - Subsection 90(3) return by LLC of unit subscription to unitholder treated as a PUC distribution
7 October 1999 APFF Roundtable Q. 8, 9920960 F - CATÉGORIE DE BÉNÉFICIAIRES Income Tax Act - Section 104 - Subsection 104(2) “class of beneficiaries” interpreted in accordance with its ordinary meaning/ s. 104(2) criteria
30 August 1999 APFF Roundtable Q. 11, 9920980 F - LEGS À UNE FONDATION Income Tax Act - Section 118.1 - Subsection 118.1(5) no gift immediately before death to a foundation if it has not yet been created
20 August 1999 APFF Roundtable Q. 13, 9920990 F - OPA ET ACTIONS PRIVILIÉGIÉES IMPOSABLES Income Tax Act - Section 248 - Subsection 248(1) - Taxable Preferred Share - Paragraph (f) - Subparagraph (f)(ii) take-over bid at an offer price in excess of the pre-bid market price does not necessarily establish an (f)(ii) FMV excess