Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.
DM'S OFFICE (3) 94-00504M/94-00834M
ADM'S OFFICE (3) STALLED 708 489 059
RETURN TO RULINGS, ROOM 303, MET. BLDG.
AUTHOR
SUBJECT OR CORPORATE FILE
March 2, 1994
XXXXXXXXXX
Dear XXXXXXXXXX:
The Honourable David Anderson, Minister of National Revenue, has asked me to reply to your correspondence of January 5 and February 2, 1994, concerning the income tax treatment of a loan forgiven by your previous employer in 1992. I regret the delay in responding.
In situations such as yours where an employer forgives a loan, the provisions of the Income Tax Act are very specific. Your case was reviewed and I must confirm that the amount of the loan forgiven is a taxable benefit. While I can appreciate your concerns, there is no authority in the Income Tax Act which would allow me to provide relief from the inclusion of this forgiven loan in income.
I trust that my comments have explained the Department's position on this matter.
Yours sincerely,
Pierre Gravelle, Q.C.
D.Zion
957-2140
February 22, 1994
4-940199