25 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
657194
Extra import data
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"field_external_guid": [
"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1991 [FE91_227 - JA91_325.335]/JA91_042 — Attribution Rules"
],
"field_proprietary_citation": [],
"field_release_date_new": "1991-01-25 07:00:00",
"field_tags": []
}
Main text
24(1)                              5-901691
                                             M.P. Baldwin
                                             (613) 957-3499
          19(1)

January 25, 1991

Dear Sirs:

This is in reply to your letter of July 20, 1990 asking if the proceeds on a life insurance policy would be considered substituted property such that the attribution rules would apply.

Based on the facts given in your letter and on a subsequent
telephone conversation (Baldwin    19(1)       Is our opinion that
the proceeds on the life insurance policy would be considered to be
substituted property.  It is also our opinion, assuming that the
grandchildren are minors, that subsection 74.1(2) of the act would
apply to attribute any non-business income or loss on the cash
proceeds or any property substituted for the cash proceeds.

We trust our comments will be of assistance to you.

Yours truly,

for Director Financial Industries Division Rulings Directorate

000042