| 19(1) | File No. 5-9238 |
| D.S. Delorey | |
| (613) 957-3495 |
January 18, 1990
Dear Madam:
Re: Deferred Salary Leave Plan
This is in reply to your letter of November 2, 1989 and further to our letter of August 23, 1989 concerning your proposed deferred salary leave plan (the "Plan").
The Plan in general complies with the relevant provisions of section 6801 of the Income Tax Regulations (the "Regulations"). However, in reviewing the Plan, we did note the following.
24(1)
24(1) We wish to clarify that neither this letter nor our letter of August 23, 1989 constitutes a "ruling". Rather, the comments therein reflect expressions of opinion only. As stated in paragraph 24 such expressions of opinion are not binding on the Department. Should you wish to obtain a binding advance income tax ruling in respect of the Plan prior to its implementation, the request should be submitted in the manner set out in Information Circular 70-6R. The current hourly fee is $65 and the minimum deposit that must be submitted with the request is currently $325.
We trust that the above comments are of assistance to you.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate