1 November 1989 Income Tax Severed Letter AC58857 - Doctrine of Constructive Receipt

By services, 22 July, 2022
Official title
Doctrine of Constructive Receipt
Language
English
Document number
Citation name
AC58857
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657948
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1989-11-01 07:00:00",
"field_tags": []
}
Main text
5-8857
                                 A.B. Adler
                                 957-8962

19(1)

November 1, 1989

Dear Sirs:

This is in reply to your letter dated October 6, 1989, concerning the possible application of the doctrine of constructive receipt to the members of a proposed employee benefit plan ("EBP") for the 24(1).

As indicated in paragraph 23 of Information Circular 70-6R we do not provide written opinions on proposed transactions. However, we are prepared to provide you with the following general comments.

The comments in paragraph 10 of Interpretation Bulletin, IT-502 with respect to constructive receipt continue to apply to all EBPs including those established for a team of professional athletes.

Should you wish to pursue this matter further we suggest that you request a ruling.

We trust that our comments will be of assistance to you.

Yours truly,

for Director Financial Industries Division Rulings Directorate