Principal Issues: Supplemental ruling in respect of our rulings letter for 2020-085832 regarding whether the proposed SERP will be an SDA.
Position: Paragraph 20 is revised to incorporate the new wording.
Reasons: The revisions do not impact the original ruling.
XXXXXXXXXX 2021-087993
XXXXXXXXXX
Dear XXXXXXXXXX:
Re: Supplemental Advance Income Tax Ruling
XXXXXXXXXX
We are writing in connection with our recent emails (XXXXXXXXXX) in regard to our advance income tax ruling number 2020-085832, that was issued to the above-referenced taxpayer on XXXXXXXXXX (the “Original Ruling”).
Capitalized terms used in this letter, but not defined herein, have the meanings given to them in the Original Ruling.
As requested, paragraph 20 of the Original Ruling is amended to read as follows:
Upon amending, and adding XXXXXXXXXX to, the CEO SERP and the VP SERP, the Company will establish a SERP DC Account for each SERP DC Member effective as of XXXXXXXXXX and make notional contributions to each SERP DC Member’s SERP DC Account in accordance with XXXXXXXXXX for the XXXXXXXXXX calendar year. Based upon the Actual Compensation and Target Compensation for each SERP DC Member for the XXXXXXXXXX calendar year, lump sum payments not exceeding $XXXXXXXXXX in total will be required to be made in respect of two SERP DC Member for the XXXXXXXXXX calendar year as described in paragraph 17(iii)(B) above.
We confirm that the rulings given in the Original Ruling, as modified by this letter, will continue to be binding on the Canada Revenue Agency subject to the same limitations and qualifications set out in the Original Ruling and in Information Circular IC 70-6R10, Advance Income Tax Rulings and Technical Interpretations, dated September 29, 2020.
Yours truly,
XXXXXXXXXX
for Division Director
Financial Industries and Trusts Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch
UNCLASSIFIED