24(1)
902562
G. Thornley
(613) 957-2101
19(1)October 29, 1990
Dear Sirs:
Re: Annuities Purchased from Charitable Organizations
This is in reply to your letter of September 18, 1990 with enclosed documents for our review.
It would appear from our examination of the documents submitted that you have met our concerns relative to the "trust" question discussed in our letter to you of August 14, 1990. We caution, however, that the actual legal arrangements between parties is a question of fact, the determination of which can only decided after the fact and often only in the courts.
Should you have an actual proposed transaction in mind and want some definitive confirmation of our comments, we suggest you apply for an advance income tax ruling in accordance with the guidelines set out in Information Circular 70-6R, a copy of which is enclosed for your information.
We trust that our comments will be helpful.
Yours truly
for Director business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch
cc. Chief of Audit Winnipeg D.O.