15 May 1991 External T.I. 9112265 F - Deduction of Carrying Charges by an EPSP

By services, 18 January, 2022
Official title
Deduction of Carrying Charges by an EPSP
Language
French
CRA tags
144
Document number
Citation name
9112265
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633733
Extra import data
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"field_external_guid": [],
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"field_release_date_new": "1991-05-15 08:00:00",
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Main text

5-911226

Dear Madam:

Re:  Technical Interpretation of Section 144 of the Income Tax Act (the "Act")

This is in reply to your letter of April 30, 1991, wherein you requested our opinion on the deduction of interest paid by an Employee Profit Sharing Plan (an "EPSP") from employer contributions to the plan for the purpose of determining required allocations to members of the EPSP.

The Department's position with respect to the deduction of carrying charges by an EPSP is stated in paragraph 2 of the Department's Interpretation Bulletin IT-379, a copy of which is enclosed for your reference.

We trust this will be satisfactory to you.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate