| October 27, 1989 | |
| Toronto District Office | Business and General |
| Source Deductions Audit | Division |
| R.J. Rousseaux | J.D. Jones |
| Group Head | (613) 957-2104 |
| File No. 7-3795 |
Subject: 24(1)
This is in reply to your memorandum of March 31, 1989, wherein you provided us with photocopies of a submission by 19(1) 19(1) acting on behalf of 24(1)
The issue centres around whether there is a benefit pursuant to section 80.4 of the Act or if the exclusion in subsection 80.4(3) of the Act is applicable and as such no benefit is deemed to have accrued to its employees.
We have reviewed the submission of 19(1) in addition to having had a meeting with officials of the Bank and their representatives and are still of the view that the exemption in subsection 80.4(3) of the Act does not apply and the employees are therefore subject to taxable benefits computed in accordance with subsection 80.4(1) of the Act as stated in our memorandum of July 25, 1988.
We also advise that we have informed 19(1) of our opinion in a telephone conversation of October 16, 1989.
for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch
c.c. Mr. R. RoyADM, Policy and Systems Branch