We have translated 5 more CRA interpretations

19 May 2026 - 11:59pm
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We have translated a further 5 CRA interpretations released in May of 1999. Their descriptors and links appear below.

These are additions to our set of 3,568 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 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
1999-05-28 7 December 1998 Internal T.I. 9819787 F - REDEVANCES RECEVABLES, FONDS PUBLICITÉ Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) royalties generated by franchisor were from its activity (a business) of providing services, and required recognition on an accrual basis
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) s. 12(1)(g) did not apply to “royalties” from franchisees that were generated predominantly by the franchisor’s services
Income Tax Act - Section 9 - Timing franchise fees were currently deductible
1999-05-14 7 May 1999 External T.I. 9832645 F - IMPACT DE 94(1)C) SUR LES FIDUCIAIRES Income Tax Act - Section 94 - Subsection 94(3) - Paragraph 94(3)(a) s. 94(1)(c) does not deem the trustees to be resident for CCPC-definition purposes
Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation shareholder that is a s. 94(1)(c) trust is not Canadian-resident for CCPC-definition purposes
7 May 1999 External T.I. 9906475 F - REEE- ÉCHEC D'UNION CONJUGALE Income Tax Act - Section 146.1 - Subsection 146.1(1) - Subscriber subscriber could be replaced by common law partner pursuant to separation agreement even before 1998
12 May 1999 External T.I. 9908085 F - RPA- RACHAT DE SERVICES PASSÉS Income Tax Act - Section 147.2 - Subsection 147.2(4) past service buybacks can be made while over 69 and in receipt of pension benefits
10 May 1999 External T.I. 9818125 F - FAMILLES D'ACCUEIL Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(h) caregiver cannot be related to the beneficiary