December 4, 1989
Mr. R.A. Short General Director Tax Policy and Legislation Branch Department of Finance 140 O'Connor Street L'Esplanade Laurier 16th Floor, East Tower Ottawa, Ontario K1A OH5
Dear Al:
Re: Attendant Care Expenses
In your of July 12, 1989, you asked whether the payment of VIP benefits directly to an attendant (rather than to the cared-for person) would be regarded by RCT as a situation where the amounts in question would be exempt income. Our Specialty Rulings Directorate says "no". A copy of their November 22, 1989 memorandum dealing with the issue is attached for your information.
Yours sincerely,
B.J. Bryson
Acting Director
Current Amendments and
Regulations DivisionDWJ/jab