DATE: May 16, 1983
TO- COMPLIANCE DIRECTORATE Audit Programs Division
FROM- CORPORATE RULINGS DIRECTORATE J.C. Clark 593-6201
ATTENTION T. McDonald Estate and Trust Group
RE: Part XII of the Income Tax Regulations ("ITR") Royalty Trusts Reporting of resource income and allowances
A correction is required to our memorandum of April 29, 1983, a copy of which is attached.
The first sentence after (1) on page 1 should be deleted and replaced with the following:
(1) Pursuant to subsection 104(13) of the Act, only $75,000 of the $90,000 payable to the beneficiaries should be included in their incomes, as this is the amount that would be the income of the trust if no deduction were made under subsection 104(6).
Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch
Attachment