We have translated 7 more CRA interpretations

25 February 2026 - 12:11am
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We have translated a CRA interpretation issued last week and 6 CRA interpretations released in October and September of 1999. Their descriptors and links appear below.

These are additions to our set of 3,491 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 26 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
2026-02-18 20 November 2025 External T.I. 2022-0940101E5 F - AAPE - Sommes déposées en fidéicommis - contrat d’arrangements préalables de services funéraires Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation funeral prepayments received in trust under the applicable Quebec Act are not assets of a funeral company
1999-10-29 9 April 1999 External T.I. 9901735 F - CREDIT D'IMPOT POUR EMPLOI A L'ETRANGER Income Tax Act - Section 122.3 - Subsection 122.3(1) how to count a month
1999-10-01 10 September 1999 External T.I. 9901545 F - DIRECTORS LIABILITY - ABIL Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) loss from debt of insolvent corporation that arose to directors as a result of their paying its GST was denied
1 September 1999 External T.I. 9901805 F - CONCESSION FORESTIERE Income Tax Regulations - Schedules - Schedule VI - Section 5 merchantable timber refers to marketable trees
Income Tax Regulations - Schedules - Schedule VI - Section 1 - Paragraph 1(a) - Subparagraph 1(a)(i) only timber from cut trees that will eventually be sold is taken into account
Income Tax Regulations - Schedules - Schedule VI - Section 2 - Paragraph 2(b) timber that is measured is merchantable timber
1 September 1999 External T.I. 9903265 F - ACTIONS ACCREDITIVES Income Tax Act - Section 66 - Subsection 66(15) - Flow-Through Share flow-through share can be issued pursuant to a subscription agreement signed by the broker as agent
General Concepts - Agency the tax consequences of a transaction are to be determined as treating the agreement of an agent as that of issued pursuant to a subscription agreement signed by the broker as agent
2 September 1999 External T.I. 9909015 F - COUT EN CAPITAL D'UNE PCMC Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A capital cost of film determined in accordance with GAAP
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose provincial capital tax is deductible
1999-09-17 31 August 1999 External T.I. 9921895 F - TRANSFERT D'ALLOCATION DE RETRAITE Income Tax Act - Section 60 - Paragraph 60(j.1) - Subparagraph 60(j.1)(ii) - Clause 60(j.1)(ii)(B) detailed example of s. 60(j.1)(ii)(B) where 50% vesting