December 4, 1989
| Mr. R.A. Short | D.W. Joy |
| General Director | 957-2083 |
| Tax Policy and Legislation Branch | |
| Department of Finance | BY HAND |
| 140 O'Connor Street | |
| L'Esplanade Laurier | F-3113/3413 |
| 16th Floor, East Tower | |
| Ottawa, Ontario K1A OH5 |
Dear Al:
Re: Attendant Care Expenses
In your of July 12, 1989, you asked whether the payment of VIP benefits directly to an attendant (rather than to the cared-for person) would be regarded by RCT as a situation where the amounts in question would be exempt income. Our Specialty Rulings Directorate says "no". A copy of their November 22, 1989 memorandum dealing with the issue is attached for your information.
Yours sincerely,
B.J. Bryson Acting Director Current Amendments andRegulations Division
DWJ/jab