| 19(1) | File No. 5-8538 |
| A.B. Adler | |
| (613) 957-8962 |
October 17, 1989
Dear Sirs:
This is in reply to your letter dated August 9, 1989 in which you requested clarification of the income tax treatment of endorsement funds received by your client, an amateur athlete, that were deposited into a trust fund for her that is administered by 24(1)
24(1)
The specific concerns raised by you namely, the treatment of (i) endorsement funds at the trust level, (ii) withdrawals from the trust to cover basic living and training expenses, and (iii) trust funds upon the dissolution of the trust are currently under review by this Department. Upon the completion of this study our position with respect to such issues will be communicated to relevant amateur athletic associations across Canada, and to other interested members of the public.
Thank you for writing to us concerning this issue.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate