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.
Principal Issues: Will the amendments to the facts and the proposed transactions in ruling 2000-001768 prevent the rulings from applying?
Position: No, but minor change in the wording of one ruling.
Reasons: The amendments are not substantive.
XXXXXXXXXX 2000-003642
Attention: XXXXXXXXXX
XXXXXXXXXX , 2000
Dear XXXXXXXXXX:
Re: XXXXXXXXXX - Amendment to
XXXXXXXXXX (the "Plan")
This is in reply to your letter of XXXXXXXXXX requesting some minor changes to an advance income tax ruling E2000-001768 dated XXXXXXXXXX, 2000 (the "XXXXXXXXXX Ruling").
As a result of your letter, the following amendments have been made to the XXXXXXXXXX Ruling:
1. Paragraph (g) of the Definitions is amended as follows:
(g) "XXXXXXXXXX " means XXXXXXXXXX or an affiliate XXXXXXXXXX.
2. 5 XXXXXXXXXX and is amended to read as follows:
5. XXXXXXXXXX.
3. 11 is amended to read as follows:
11. XXXXXXXXXX fee of $XXXXXXXXXX. This XXXXXXXXXX over the course of the Plan.
XXXXXXXXXX.
4. 15 is amended to read as follows:
15. Subject to 16 below, XXXXXXXXXX for a particular XXXXXXXXXX reaches $XXXXXXXXXX, the XXXXXXXXXX will direct the XXXXXXXXXX to contribute XXXXXXXXXX to an RRSP XXXXXXXXXX for himself/herself, to a non-registered account at the XXXXXXXXXX for himself/herself or to an RRSP at the XXXXXXXXXX for his/her spouse.
We confirm that the changes to the Definitions, Facts and Proposed Plan as set out above will not affect rulings A, B and D given in the XXXXXXXXXX Ruling, and they will continue to be binding on the Canada Customs and Revenue Agency (the "Agency") subject to the conditions stated therein. Ruling C is replaced with the following, and is binding on the Agency subject to the conditions as set out in the XXXXXXXXXX ruling:
C. Where the XXXXXXXXXX directs the XXXXXXXXXX to contribute XXXXXXXXXX in the XXXXXXXXXX to an RRSP of the XXXXXXXXXX or the XXXXXXXXXX spouse, the contribution will constitute a "premium" to the XXXXXXXXXX as that term is defined in subsection 146(1) of the Act, and will be deductible in computing the XXXXXXXXXX income for a taxation year subject to the limitations in subsection 146(5) or 146(5.1) of the Act.
Yours truly,
XXXXXXXXXX
for Director
Financial Industries Division
Income Tax Rulings Directorate