5-913492
Dear Sir:
Re: Deferred Salary Leave Plans — Leave Period
This is in response to our telephone conversation(Baldwin/19(1))on December 11,1991 concerning paragraph 6801(a)(i)of the Income Tax Regulations.
Our position in the past, with respect to paragraph 6801(a)(i), has been that the minimum six month leave of absence could only include those months during which a teacher would normally be required to report to work. We have recently re-evaluated our position and have decided that if a teacher is employed but, under his or her contract of employment, is not required to report to work for a period between semesters, the time between semesters may be included in the calculation of the minimum six month leave of absence.
We trust the above comments will be of assistance to you.
Yours truly,
for DirectorFinancial Industries DivisionRulings DirectorateInformation Act l'information