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.
ADM'S OFFICE (3) ADM # 969554
PENDING COPY
RETURN TO I.T. RULINGS & INT.
15TH FLOOR, ALBION TOWER
March 14, 1996
XXXXXXXXXX
March 14, 1996
Dear XXXXXXXXXX:
I refer to your recent conversation with Mr. Barry Lacombe, Assistant Deputy Minister of the Verification, Enforcement and Compliance Branch of the Department concerning flexible benefit plans.
I am pleased to inform you that this Branch initiated a project earlier this year to publish an interpretation bulletin on the subject of flexible benefit plans. An initial draft of the bulletin has been completed and we are in the process of consulting with interested parties to ensure that it fully addresses the issues of concern.
I regret that I cannot provide you with an estimate of the length of time it will take to complete the consultative process since the completion date will depend to a large extent on the comments that we receive. However, we are doing our utmost to complete the bulletin as quickly as possible without sacrificing any clarity or completeness in the bulletin.
In the meantime, if you or your associates would like any information relating to the tax consequences associated with a flexible benefit plan, you may contact Mr. Bryan Dath, Director of the Business and General Division of Income Tax Rulings and Interpretations Directorate. He can be reached by telephone at (613) 957-2089 or by writing to 15th Floor, Albion Tower, 25 Nicholas Street, Ottawa, Ontario, K1A 0L8. In addition, the local tax services offices have installed an electronic database called LAD which contains the letters of interpretation written by this Branch. This database is available to the public and includes Departmental opinions on flexible benefit plans.
I would also like to take this opportunity to thank you for offering to let us publish a severed version of the ruling we issued to your company in December of 1994. While we have decided to publish an interpretation bulletin instead, I am pleased to inform you that it is our intent to make all advance income tax rulings issued by this Branch available to the public in a severed form through the electronic database.
Thank you for bringing your concerns to our attention.
Yours sincerely,
Denis Lefebvre Assistant Deputy Minister Policy and Legislation Branch
A. Humenuk
957-2134
March 12, 1996