| November 9, 1989 | |
| VANCOUVER DISTRICT OFFICE | HEAD OFFICE |
| Chief of Audit | Rulings Directorate |
| Leasing & Financing Section | |
| Attention: S. Tom Markota | Kevin Donnelly |
| Section 142-13 | 957-3500 |
| File No. 5-8950 |
Subject: Proposed adjustments - inducements 24(1)
With respect to your audit of the above-noted taxpayer and the July 18, 1989 letter written to us by 24(1)
19(1) reiterated his client's position as set out in his previous written representations and was given the opportunity to fully discuss his views and his position.
19(1) was advised that the Department's position in 9(c) of IT-359R2 was intended to cover all taxpayers who were in a position to negotiate leases to obtain, demand or increase inducements to become tenants.
24(1)
21(1)(b)
However, we agree with the District Office that the decision to include in income the inducements received by 24(1) properly reflects the Department's policy and position on the taxation of inducements.
We advised 19(1) by telephone of our position and we see no reason why the inducement adjustments proposed by the Vancouver Audit Division should not be made.
ChiefLeasing & Financing SectionFinancial Industries DivisionRulings Directorate