| Source Deductions Division |
| Personal and General Section |
| A. Bissonnette, Director |
| Attention: Eric Hammond |
D.O./T.C. Support Services Section
Travel Miles Program
We are replying to your memorandum dated June 10, 1993 concerning a letter you received from XXXXXXXXXX dated May 26, 1993.
You have asked us to review your draft reply and offer any comments which we might have. The letter from XXXXXXXXXX is set up in the format generally used for advance income tax rulings. The major difference between their request and an advance income tax ruling is that their request is submitted on a "no-names" basis and we have not had an opportunity to review the underlying documentation upon which the stated facts were derived. When we receive requests for confirmation of the tax consequences on a "no-names" basis, we advise the writer that we will not confirm the tax consequences otherwise than by way of an advance income tax ruling.
With respect to the substance of your letter, we agree with your comments but we wonder why XXXXXXXXXX has restricted their request to the redemption of travel miles for airfare when the program in question also permits the redemption of travel miles for hotel accommodation and car rentals. In our view, the tax treatment relating to the redemption of the latter is treated in substantially the same manner as the former. In the case of hotel accommodation and automobile rentals however, the value of such a bonus is not subject to the same discount policy as for unconfirmed airfare.
We trust this is satisfactory.
B.W. Dath DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch