Revenue Canada Taxation Head Office
K.B. Harding (613) 957-2129
June 10, 1988
Dear Sirs:
This is in reply to your letter of March 15, 1988 wherein you attached a copy of a letter which your firm received from this Division dated October 31, 1985 (A-1875) concerning paragraph 115(2)(c.1) of the Income Tax Act.
You requested we confirm that the position set out in A-1875 continues to be Revenue Canada's position on this subject.
We confirm that our position continues to be the same in the fact situation described in A-1875. However, we would caution that our comments set out in A-1875 would only apply to a reasonable relocation allowance paid by the tax exempt entity to the non-resident individual.
We trust these comments are suitable for your purposes.
Yours truly,
for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch