22 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
657582
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_099 — Fees Paid to Trustees"
],
"field_proprietary_citation": [],
"field_release_date_new": "1991-01-22 07:00:00",
"field_tags": []
}
Main text
Mr. H.L. Jones
Director
General Tax Policy                      903572
Goods and Service Tax                   L. Holloway
Revenue Canada Customs                  (613) 957-2104
  and Excise
Ottawa, Canada
K1A OL5

Attention: Mr. Duncan Jones

January 22, 1991

Dear Sirs:

Re: Fees Paid to Trustees

This is in response to your letter dated November 4, 1990 concerning the income tax treatment of trustee fees.

Trustee fees are earned by an individual as a result of their appointment as a trustee. Similar to the position of executors, if one was in the business of being a trustee, (e.g. a trustee in bankruptcy) trustee fees earned would be taxable as business income. Any fees earned as a trustee by an individual who is not engaged in this activity as a business, would be taxable as income from an office under subsection 5(1)(a) of the Income Tax Act.

We trust this is the information you require.

Yours truly,

B.W. Dath Director Business and General Division. Rulings Directorate Legislative and Intergovernmental Affairs Branch

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