| December 14, 1989 | |
| TO: HAMILTON DISTRICT OFFICE | FROM: HEAD OFFICE |
| Specialty Rulings | |
| Directorate | |
| Mike Muirhead | |
| Special Investigations Section | File No. 7-4455 |
SUBJECT: Taxation of Pension Plan Surplus
We are writing in reply to your memorandum of October 18, 1989 wherein you requested our views regarding the appropriate income tax treatment, for both vendor and purchaser, of a Pension Plan Surplus.
Our understanding of the facts in this case is as follows:
24(1)
Our Comments
We are enclosing, for your information, copies or correspondence with the Vancouver District Office regarding 24(1) the content of which is self-explanatory.
Although the facts in this case are not identical to the 24(1) case, we believe there are sufficient similarities between the two situations such that the opinions set our in the November 18, 1982, memorandum would have equal application in this case.
24(1) 21(1)(b)
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