Principal Issues: [TaxInterpretations translation] Does Section 7 apply in a situation where a trust created under an Employee Stock Ownership Plan (the "Plan") acquires all of the shares of USCO and each year the Plan credits to a notional account of each Participant (including Participants resident in Canada and employees of CANCO) a pro rata share of the shares so acquired?
Position: Yes, the request for rulings was withdrawn by the representative.
Reasons: Where shares are credited to a particular Participant's notional account, subsection 7(2) applies because a trustee holds a security, in trust or otherwise, conditionally or unconditionally, for an employee.
XXXXXXXXXX
December 3, 2009
Dear Madam,
Subject: XXXXXXXX
Request for Advance Income Tax Rulings
This is further to our telephone conversation of November 27, 2009 (Goulet/XXXXXXXXXX) where you advised us that you are withdrawing your requests for advance income tax rulings of February 25, 2009 and September 1, 2009.
We have closed our file on this issue. An invoice for the time spent reviewing this request for advance income tax rulings will be sent to you under separate cover.
Best regards,
Ghislain Martineau
Manager of the Financial Sector and Exempt Entities Section
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch.