| November 16, 1989 | |
| Penticton District Office | Head Office |
| Rulings Directorate | |
| B. Sixsmith | Financial Industries Division |
| Chief of Audit | A.B. Adler |
| (613) 957-8962 | |
| File No. 7-4408 |
Subject: 19(1)
This is in reply to your memorandum (received October 10, 1989) prepared by Mr. R. Pronger in Business Audit regarding the treatment of certain amounts 24(1)
The information provided by you with respect to the amounts in question was discussed with senior counsel and two managers in our Specialty Rulings Directorate i.e. those who deal employment and unincorporated partnership issues respectively.
24(1)
(We understand that it is not uncommon for professional accountants and lawyers to act as nominee shareholders and officers of client corporations in the ordinary course of carrying on their businesses and to treat the income therefrom as business income).
24(1)
It is our general position that when a taxpayer contributes a portion of a reasonable retiring allowance to his RRSP such transfer will be deductible under paragraph 60(j.1) of the Act provided the requirements of that provision are fully met.
for Director Financial Industries Division Rulings Directorate