| July 4, 1989 | |
| TORONTO DISTRICT OFFICE | HEAD OFFICE |
| Estates & Trusts | Rulings Directorate |
| Financial Industries Division | |
| F. Francis | |
| 957-3596 |
SUBJECT: 24(1) Employee Benefit Plan (the "Plan") 24(1)
Please find attached a letter from 24(1) in respect of the above-noted Plan.
It is our understanding that there is a dispute between 24(1)
In our opinion, the income earned on the funds in the suspense account should be included in the income of the Plan for the year pursuant to subsection 32.1(3) of the Income Tax Act.
However, since this issue is in respect of a completed transaction, we are submitting the matter for your consideration and reply.
for Director Financial Industries Division Rulings Directorate