5-8571
19(1) B.G. Dodd
613-957-9769September 14, 1989
Dear Sirs:
Re: Income Averaging Annuity Contract
We are writing in reply to your letter dated August 23, 1989 requesting clarification of the application of an advance income tax ruling issued by this Department.
Advance income tax rulings bind the Department in respect of the transactions proposed therein and the taxpayers in respect of whom the ruling issued. In the absence of confirmation that the ruling to which you refer applies to your, we are unable to discuss its specific contents and application. However, we are able to advise that pursuant to paragraph 56(1)(d) of the Income Tax Act, amounts received under an income averaging annuity contract must be included in income in the year of receipt.
We hope you will find this to be of assistance.
Yours truly,
for Director Financial Industries Division Rulings Directorate