17 January 1991 Income Tax Severed Letter

By services, 22 July, 2022
Language
English
Document number
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656925
Extra import data
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Main text

January 17, 1991

Current Amendments and                  Financial Industries
  Regulations Division                    Division
                                        D.S. Delorey
                                        957-3494
Attentions:  R. D'Aurelio
             Director    
                                        5-901540

Subsection 110.6(1) "Investment Income" - 1990 Technical Bill

We wrote to you on January 11, 1989 suggesting that annuity income did not represent income from property for the purposes of the definition of "investment income" in subsection 110.6(1) of the Act.

We have recently had occasion to reconsider this matter and it is now our view that income taxed under paragraphs 56(1)(d) to (d.2) of the Act is income from property for the purposes of the Act. We enclose for your information copies of recent correspondence relevant to this issue

                              21(1)(b)

Director General Rulings Directorate Legislative & Intergovernmental Affairs Branch

000323