| 19(1) | File No. 5-8889 |
| A.B. Adler | |
| (613) 957-8962 |
November 27, 1989
19(1)
This is in reply to your letter dated October 11, 1989, and is further to ours of August 11, 1989, concerning the income tax treatment of the interest portion of instalment payments made to purchase past service for pension purpose.
You requested our views with respect to your eligibility to bring forward, under subsection 8(8) of the Income Tax Act ("Act"), amounts of instalment interest from 1986 and 1987, and to claim deductions in respect of such amounts in 1988 upon your filing a notice of objection for that year.
Our role is interpretive rather than advisory and, therefore, we are not in a position to advise you as requested. However, paragraph 4 of I.C. 75-7R3 (copy enclosed) and in particular (e) therein explains our general position regarding a reassessment of an income tax return to create a refund.
We trust that our comments will be of assistance to you.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate