Revenue Canada Taxation Head Office
W.E. Douglas (613) 995-0051
May 22, 1986
Dear Sirs:
This is in reply to your letter of January 29, 1986 concerning the timing of deductions for retiring allowances.
Although it is our view that retiring allowances are, in most cases, deductible when paid, we have, in specific circumstances, confirmed that such amounts are deductible when they became payable.
If you have a specific case in mind, you may wish to obtain an advance income tax ruling. We have enclosed a copy of Interpretation Bulletin IT-337R2 which discusses Retiring Allowances and a copy of Information Circular 70-6R which outlines the requirements for an advance ruling request.
Yours truly,
for Director Financial Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch