| 19(1) | 902776 |
| R.B. Day | |
| (613) 957-2136 |
December 13, 1990
19(1)
We are writing in reply to your letter of September 11, 1990, in which you requested an advance income tax ruling with respect to the deductibility of travel expenses incurred by your corporations.
Since your request does not involve a proposed transaction but relates to a series of on going transactions, we are unable to provide you with a binding advance income tax ruling. We are however prepared to offer an opinion regarding the situation set out in your letter.
24(1)
Our Comments
In our opinion 24(1) The interaction of paragraphs 18(1)(a) and 18(1)(h) of the Income Tax Act (the "Act") prohibit the deduction of these expenses 24(1)
We are enclosing for your information a copy of Interpretation Bulletin IT-487, entitled "General Limitation on Outlays or Expenses" which explains the operation of section 18 in more detail.
The deposit which accompanied your request will be returned under separate cover.
We trust that the above comments are of assistance to you.
Yours truly,
for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch
Attachments
c.c. Director Halifax District Taxation Office