| 24(1) | 5-903099 |
| W.C. Harding | |
| (613) 957-8953 |
19(1)
November 28, 1990
Dear Sirs:
This is in reply to your letter of November 5, 1990, wherein you requested rulings with respect to the deductibility of contributions to be made to various Deferred Profit Sharing Plans ("DPSPs") in 1990 or 1991.
Since the subject matter of your letter relates to proposed transactions, we are unable to provide a ruling except when it is requested in accordance with the procedures set out in the Department's Information Circular 70-6R2 a copy of which is enclosed. A ruling when properly requested is binding on the Department.
While we can not provide you with any specific replies to your enquiries we can note that paragraph 18(1)(j) of the Income Tax Act (the "Act") provides a deduction in computing a taxpayer's income for tax purposes of contributions made to any DPSPs in accordance with the terms of the DPSP, but subject to the limitations contained in subsection 147(8) of the Act.
We can also note that, for years after 1990, the provisions of section 147 of the Act have been amended to allow the deduction of all contributions made in accordance with the terms of a DPSP to the extent they comply with subsection 147(5.1) of the Act. Detailed information on these limits is available through your local District Taxation Office.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate