Revenue Canada Taxation Head Office
Mr. G. Renaud Staff Benefits Officer National Research Council Personnel Branch Ottawa, Ontario K1A 0R6
W.E. Douglas 995-0051
May 30, 1986
Dear Mr. Renaud:
Re: Retiring Allowances for Post-doctorate Fellows:
This is with respect to your letter of April 17, 1986 concerning the payment of retiring allowances to Post-doctorate Fellows.
As we discussed, since a retiring allowance is defined in subsection 248(1) of the Income Tax Act as an amount received after retirement from employment in recognition of long service or in respect of a loss of employment, it is our view that amounts paid to Post-doctorate Fellows would not qualify as a retiring allowance as there was no employee-employer relationship between those individuals and the National Research Council.
We regret that our reply could not have been more favourable.
Yours truly,
for Director Financial Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch