REVENUE CANADA, TAXATION MEMORANDUM
DATE April 25, 1989
TO Publications Division Director
FROM Financial Industries Division
F. Francis 957-3496
This is in response to your enquiry regarding the possible publication of issued advance income tax ruling E-111 with respect to an Employee Incentive Plan.
In our opinion this ruling is not suitable for publication since, under current legislation, the plan would be considered a Salary Deferral Arrangement under subsection 248(1) of the Income Tax Act. The rulings issued would therefore have no applicability in respect of current employee incentive plans.
for Director Financial Industries Division Rulings Directorate