24(1) 5-910987 D.S. Delorey (613) 957-3494
19(1)
April 26, 1991
Dear Sir:
Re: Employee Profit Sharing Plan ("EPSP") Non-Resident Employees
This is in reply to your letter of March 28, 1991 concerning the above referenced matter.
You mention that your client is considering making a contribution to an EPSP on behalf of a number of its employees who will be performing services outside Canada. With respect thereto, you cite certain facts and assumptions and ask us to confirm your understanding of the income tax implications inherent therein.
As explained in paragraph 21 of Information Circular 70-6R2, to which you refer in your letter, written opinions are given only in respect of interpretations of specific provisions of the law. Written opinions on the tax implications inherent in proposed transactions are given only in response to advance ruling requests submitted in the manner set out in information Circular 70-6R2.
We are prepared to consider your request further should you decide to request an advance ruling. We trust that our comments satisfactorily explain the Department's position.
Yours truly,
for Director Financial Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch 000081