Dear Sirs:
Re: Quebec Tax Abatement/Non-Residents
This is in reply to your letter dated May 17, 1991 concerning the so called "16.5% Quebec abatement".
The "16.5% Quebec abatement" of Canadian federal income tax in respect of employment income earned in Quebec is dealt with by subsection 120(2) of the Canadian Income Tax Act in interaction with Part XXVI of the Income Tax Regulations and section 27 of the Federal-Provincial Fiscal Arrangements and Federal Post-Secondary Education and Health Contributions Act R.S.C. 1985, c. F-8, as amended. We note that in certain cases remission orders issued under the Financial Administration Act R.S.C. 1985, c. F-8, as amended, such as the Income Earned in Quebec Income Tax Remission Order. 1988, may also be relevant and applicable in respect of this matter.
We, of course, cannot provide an opinion as to whether the foregoing statutory provisions apply or how they apply in any particular case without knowing all of the relevant facts.
Yours truly,
for DirectorReorganization and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch