27 April 1990 Income Tax Severed Letter ACC9137 - Employees Retirement Plan

By services, 22 July, 2022
Official title
Employees Retirement Plan
Language
English
Document number
Citation name
ACC9137
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657063
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-04-27 08:00:00",
"field_tags": []
}
Main text

April 27, 1990

FROM - HEAD OFFICE Financial Industries Division M. Shea-DesRosiers

TO - EDMONTON DISTRICT OFFICE R. Kisinger Chief of Basic and Business Files

     Attention: Don Burns
                Business Audit Manager
SUBJECT:             24(1)
         Employees Retirement Plan ("Plan")

This is in reply to your memorandum of March 29, 1990 concerning the above-mentioned subject. The facts are recited in a memorandum from your District Office dated August 17, 1988 and in our reply of September 26, 1988.

We have verified with Registrations that the Plan in question, while it will be terminated, is still considered active for Revenue Canada purposes since the funds have not yet been distributed.

It follows that the question of waivers no longer applies. A trust still exists which is a tax-exempt entity pursuant to paragraph 149(1)(o) of the Income Tax Act (the "Act") and the interest that is being earned in the fund is therefore not subject to tax. When the funds are distributed, the employees will include the amount received in their income under paragraph 56(1)(a) of the Act.

We trust the above comments will be of assistance to you.

Wayne Douglas Chief Deferred Income Plans & Trusts Section Financial Industries Division Rulings Directorate