Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ADRC.
Principal Issues:
The words "by the Eligible Director" are being added to clarify the wording in two rulings given in Ruling 2002-011724.
Position: Changes required for clarification purposes.
Reasons: The changes do not affect the rulings provided.
XXXXXXXXXX 2002-012989
XXXXXXXXXX, 2002
Dear XXXXXXXXXX:
Re: Supplemental Advance Income Tax Ruling
XXXXXXXXXX (the "Corporation") XXXXXXXXXX
This supplemental ruling is further to Ruling number 2002-011724 dated XXXXXXXXXX, 2002.
For clarification purposes, the words "by the Eligible Director" should be inserted in rulings D. and E. of Ruling 2002-011724, such that the rulings now read:
D. When cash is received by the Eligible Director in satisfaction of a resident Eligible Director's DSUs, as described in 2.g) above, the resident Eligible Director will include the amount paid by the Corporation, before withholding taxes, in his or her income for the year under paragraph 6(1)(c) of the Act.
E. When cash is received by the Eligible Director in satisfaction of a non-resident Eligible Director's DSUs, as described in 2.g) above, the non-resident Eligible Director will include the amount, to the extent attributable to services rendered in Canada, paid by the Corporation, before withholding taxes, in his or her income for the year under paragraph 6(1)(c) and subparagraph 115(1)(a)(i) of the Act.
We confirm that the above changes will not affect the rulings given in Ruling 2002-011724 and the rulings will continue to be binding on the Canada Customs and Revenue Agency as indicated therein.
Yours truly,
XXXXXXXXXX
for Director
Financial Industries Division
Income Tax Rulings Directorate