We have translated 7 more CRA interpretations

26 May 2025 - 10:52pm
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We have translated a CRA interpretation released last week and a further 6 CRA interpretations released in August of 2000. Their descriptors and links appear below.

These are additions to our set of 3,209 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 24 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
2025-05-21 2 April 2025 External T.I. 2019-0818321E5 F - Reverse Earnout Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) capital gains and then capital loss treatment of an asset sale made on a reverse earnout basis accepted, where the targets were not achieved
Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) no capital gains reserve is available for a reverse earnout
2000-08-04 14 July 2000 External T.I. 2000-0015245 F - ÉTUDIANT A TEMPS PLEIN - T2202A Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(b) following of institution's policy for recognizing full-time students
10 July 2000 Internal T.I. 2000-0022027 F - OBLIGATION LÉGALE DE PAYER UNE DÉPENSE Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) not contingent if only uncertainty as to timing of payment and not as to obligation to pay
10 July 2000 Internal T.I. 2000-0022907 F - Allocation de fin de carrière - revenu gagné Income Tax Act - Section 146 - Subsection 146(1) - Earned Income “end-of-career” allowances received by physician were earned income given his continued work
5 July 2000 Internal T.I. 2000-0024977 F - PENSION ALIMENTAIRE- DATE D'EXECUTION Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day interim support order that replaced separation agreement established a commencement day
5 July 2000 Internal T.I. 2000-0025487 F - PENSION ALIMENTAIRE Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount - Paragraph (a) written agreement must be what established the support obligation
23 September 1998 External T.I. 9800555 F - FIDUCIE SUCCESSIVE - FIDUCIE TESTAMENTAIRE Income Tax Act - Section 248 - Subsection 248(9.1) trusts for the minor children which, by will, were to receive a gift over of the remainder from a spousal trust established by that will, were deemed by s. 248(9.1) to be testamentary trusts
Income Tax Act - Section 108 - Subsection 108(1) - Testamentary Trust remainder trusts required by the will to be established for the children after the termination of the testamentary spousal trust were deemed to be testamentary trusts by s. 248(9.1)