| September 19, 1989 | |
| Mr. A. Bissonnette | Current Amendments and |
| Director | Regulations Division |
| Revenue Programs Division | R.D. Weil / 957-2066 |
| Assessing and Enquiries | |
| Directorate | F-3173 |
1990 Instalment Guide for Corporations
As requested in your memo of August 9, 1989, we have reviewed the above document from a tax policy viewpoint.
From our review of the changes proposed in the 1989 edition of the above Guide, we did not note any statements which were contrary to intended tax policy.
General Comments
1. With the addition of new taxes under Parts I.3, VI, IX and XII.3, much of the Guide is now devoted to special taxes that affect very few taxpayers (e.g. - the new Part VI tax on large financial institutions only affects 10 companies). You may wish to cover all taxes except Part I and VI.1 taxes in an Information Circular rather than in the above Guide in future years.
2. Under the heading "Credit Unions" you may wish to mention subsection 161(3) as well as subsection 157(2).
3. There are some references to Tax Reform continued from the 1989 Guide which you may wish to drop now.
4. Some of the references to the April, 1989 Budget imply the implementing legislation has been passed while others do not. You may wish to make these references uniform.
5. You may consider highlighting those changes to the Guide which are new for 1989.
6. The comments under "Rates of Tax" seem to imply that Bill C-75 concerning the 1988 Canada - Nova Scotia Offshore Petroleum Resources Accord Implementation Act has not been passed, whereas that Bill received Royal Assent on July 21, 1988 although it has not yet been proclaimed in force. Perhaps this should be clarified. In any event, footnote (1) is not applicable to Newfoundland tax.
7. You may wish to highlight the important change to subsection 248(7) concerning the date of receipt of instalments at the beginning of the Guide.
8. The comments under "Part I.3 Tax on Large Corporations" which refer to "twelve payments equal to 1/12 of..." may not be correct for taxpayers with short tax years.
9. In the form at the end of the Guide, it appears that the "Sub-Total" includes "Estimated Taxable Income" which is not intended.
10. Enclosed is a copy of our handwritten review notes and comments which may be of use to you in the final editing process.
Please note that we have not reviewed this Guide from a technical viewpoint as this is being done in our Branch by Technical Interpretations Division.
B.J. Bryson Acting DirectorCurrent Amendments and Regulations Division
RDW/jab