8 May 1991 Income Tax Severed Letter

By services, 22 July, 2022
Language
English
Document number
Severed letter type
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
658010
Extra import data
{
"field_external_guid": [
"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1991 [JN91_149.150 - MA91_334.338]/MA91_196 — Annual Clothing Reimbursement Taxable Benefit to Employees"
],
"field_proprietary_citation": [],
"field_release_date_new": "1991-05-08 08:00:00",
"field_tags": []
}
Main text
19(1)          910690
                                        R.B. Day                                        (613) 957-2136

May 8, 1991

          19(1)

We are writing in reply to your letter of March 6, 1991, wherein you requested our opinion as to whether or not the decision of the Federal Court of Appeal in the Queen v Huffman, 90 DTC 6405, would alter the conclusions reached in our previous letter to you dated February 15, 1990.

Our Comments

It is our view that the decision in this case would not alter the conclusions set out in our previous letter. The Huffman case was decided on its own particular finding of fact and would only have application in factual situations virtually identical with the Huffman decision. In view of the foregoing it is our opinion that the annual clothing reimbursement is a taxable benefit to the employees in receipt of the reimbursement, as discussed in our letter of February 15, 1990.

We trust that these comments are of assistance to you.

Yours truly,

for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch

                                                           000196