| 19(1) | 901366 |
| R. Mundell | |
| (613) 957-2139 | |
| EACC9426 | |
| July 18, 1990 |
Dear Sir:
Re: Donations and Trusts
This will reply to your letter of June 20, 1990 requesting an advance income tax ruling concerning purported "gifts" from patients.
24(1)
We are unable to rule in this matter, as what constitutes a gift in any particular circumstance is a question of fact. Based on the information provided we would be unable to give you a favourable ruling in any case. Your advance fee of $325.00 will therefore be returned to you under separate cover.
For your information we offer the following general comments.
OUR COMMENTS
24(1)
24(1)
We hope these comments will be helpful.
Yours truly,
for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch