27 March 1991 Income Tax Severed Letter

By services, 22 July, 2022
Language
English
Document number
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656300
Extra import data
{
"field_external_guid": [
"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1991 [MA91_339 - 903198]/MR91_072 — Long-Term Disability Plan"
],
"field_proprietary_citation": [],
"field_release_date_new": "1991-03-27 07:00:00",
"field_tags": []
}
Main text

March 27, 1991

Toronto District Office                 Head Office
G.C. Vandervoort                        Rulings Directorate
Chief of Verifications                  R.B. Day
  and Collections                       (613) 957-2136
                                        910488
          19(1)
Application of ITAR 19
          24(1)
Further to our telephone conversation of March 19 , 1991, we are
forwarding a copy of the request for an advance income tax ruling
dated February 15, 1991, submitted on this taxpayer's behalf by  
19(1)19(1)19(1)           will, in due course, be forwarding copies of the
LTD plan plus any amendments thereto, for your determination as to
whether it qualifies as an exempt plan or an amended plan.

Our Comments

From our review of the relevant documentation attached to the ruling request, it is our view that the

                         24(1)
                                                     As a
consequence, whether or not the taxpayer receives 100% of his
disability benefits tax free, or apportioned on the basis discussed
in paragraph 21 of  IT-428
, will depend on the status of the LTD
plan.

Should you require further information in this regard, please contact the writer.

B.W. Dath Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch

000072