5-903616
Subject: Tax Treatment - Allowance in Lieu of Salary
19(1)
As discussed in our telephone conversation of January 11, 1991(Cousineau/Guglich), the attached correspondence is referred to you, since it pertains to the tax treatment of payments the taxpayer is currently receiving.
Although the taxpayer's representative refers to the payments as training allowances the documentation clearly states that they are an 24(1) Since the payments do not appear to be training allowances the Indian Remission Order respecting training allowances would not apply in this case. In addition the payments could not be considered a scholarship.
24(1)
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