| March 9, 1990 | |
| Mr. E. Noel de Tilly | Provincial and International |
| Director | Relations Division |
| Appeals and Referrals Division | B. Fioravanti |
| 957-2073 | |
| 24(1) | HBW 9586-1 |
SUITORS' FUNDS IN TRUST
This is further to your memorandum of February 25, requesting our comments with respect to the above-noted matter.
As we understand it, "suitor funds" consist of amounts paid into court which are held for the benefit of minors and unspecified persons. With respect to these funds, Revenue Canada has taken the position that the Province, in its capacity as trustee of the funds, must report the interest earned. Following from this, the Province should report the income earned on trust funds yearly and must remit tax on trust income in cases where the beneficiary has not been specifically identified.
21(1)(b)
We would appreciate being kept advised on the progress of this case. By the same token, we would be prepared to offer our assistance if requested.
Your file is returned herewith.
C. SavageA/DirectorProvincial and International Relations Division
Attachment
no6-19BF/sgFile copy Sequence file Author's copy Chrono file (2)Reading file