| 19(1) | File No. 1-823 |
| G. Ozols | |
| (613) 957-2127 |
Dear Sir:
Re: Supplementary Income Tax Ruling Structured Settlement 24(1)
This is in reply to your letter of September 15, 1989 with attachments concerning the advance income tax ruling we issued on March 23, 1989 regarding a structured settlement for 24(1).
You have requested that you be advised should there be anything in the judgement of Madam Justice Krindle that is not in accordance with the advance ruling we gave.
It is not the Department's policy to ascertain that all the facts and condition s set forth in advance rulings requested and given are met and thus binding on the Department once the transaction is completed. This can only be done when an audit of the affairs of a taxpayer is conducted by our District Offices.
As long as the facts and conditions as set forth in the advance rulings are met, and there appears to be no reason to believe otherwise in this case, the advance rulings are binding.
We trust the above comments will be of assistance to you.
Yours sincerely,
for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch