| 5-921970 | |
| 24(1) | D.S. Delorey |
| (613) 957-8953 |
Attention: 19(1)
August 7, 1992
Dear Sirs:
This is in reply to your letter of May 21, 1992, addressed to the Toronto District Taxation Office and referred to this Division for reply, concerning computations under paragraph 60(j.1) of the Income Tax Act (the "Act").
More particularly, you refer to advance tax ruling ATR-48 and seek clarification of the manner in which the Department arrived at the number 10 set out in 6(b)(i) of that ruling. You suggest in your letter that this number should be 11, being the number of years or part years from 1980 to 1990.
Our Comments
As noted in 1 of ATR-48, Mr. A was not employed by Employerco in 1983. Accordingly, the number 10 set out in 6(b)(i) of the ruling was calculated as follows:
(a) 3, being the number of years or part years from 1980 to 1982, plus
(b) 7, being the number of years or part years from 1984 to 1990.
Had Mr. A been employed by Employerco at any time in 1983, the number of years in 6(b)(i) of ATR-48 would have been 11.
We trust our comments are of assistance.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate