1 November 1989 Internal T.I. 58857 F - Doctrine of Constructive Receipt

By services, 18 January, 2022
Official title
Doctrine of Constructive Receipt
Language
French
CRA tags
n/a
Document number
Citation name
58857
Severed letter type
Technical Interpretation - Internal
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
631021
Extra import data
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Main text
19(1) File No. 5-8857
  A.B. Adler
  957-8962

November 1, 1989

Dear Sirs:

This is in reply to your letter dated October 6, 1989, concerning the possible application of the doctrine of constructive receipt to the members of a proposed employee benefit plan ("EBP") for the 24(1).

As indicated in paragraph 23 of Information Circular 70-6R we do not provide written opinions on proposed transactions.  However, we are prepared to provide you with the following general comments.

The comments in paragraph 10 of Interpretation Bulletin, IT-502 with respect to constructive receipt continue to apply to all EBPs including those established for a team of professional athletes.

Should you wish to pursue this matter further we suggest that you request a ruling.

We trust that our comments will be of assistance to you.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate