January 22, 1991
Ed Gauthier A. Seidel Director 957-8960 Special Audits Division
4-910178
Deputy Minister's Mail
We are referring the attached letter from 19(1) to the Deputy Minister for your response as the principal-concerns expressed are compliance with paragraph 300(2)(c) of the Income Tax Regulations. This matter has previously been referred to MaryLove day of your division for consideration.
19(1) principal concern is that the Department is not administering the tax law with respect to non-registered annuities consistently. He states that the Department has failed to protect his "rights" by failing to detect errors and inconsistencies in statements of annuity income (T4A's) compiled and submitted by insurance companies because the T4A'S are not checked for accuracy by the Department. He is also of the view that the Department should initiate any action to correct deficiencies in the Income Tax Regulations which prevent the Department from discharging its responsibility to verify the accuracy of statements of taxable income reported by non-registered annuity holders.
The issue of issue to publish ann Interpretation Bulletin has been considered by the Publications Division and it is their view that there would be an insufficient number of taxpayers who would benefit therefrom to justify the cost.
We have attached copies of our previous memorandum to Mary Loveday and the memorandum from publications to Marcel Clement. Also attached are the two letters previously sent to (19(1)) under Mr. Gravelle's signature.
Director Financial Industries Division Rulings Directorate
Attachments 000088