| 19(1) | E.E. Campbell |
| (613) 957-2067 |
December 19, 1990
Dear: 19(1)
We received your most recent letter on your tax status. We assume that you have now received our letter of November 23 which responds to your earlier letter of November 1, with the schedule.
We hope that the comments were of help to you. It is important to understand that the gross amount of income will be brought into income in Canada and that a credit will be given for South African tax. It is not the income after deducting South African tax that is brought into Canadian income, but rather the amount before deducting South African tax. The effect is that you pay the higher of the two rates.
It seemed from your calculation of the tax that it was higher in South Africa so that the credits should eliminate the Canadian tax. If there is an amount that is not taxable in South Africa, which now seems not to be the case, it could still be subject to tax in Canada, depending on the nature of the amount.
We hope that the information which we have provided will assist you. We did not address all of the options you raised since the results for each would be arrived at in a similar fashion. If you have further questions please let us know.
Yours sincerely,
Christine SavageActing DirectorProvincial and InternationalRelations Division