30 November 1996 Ruling 9700343 - mutual fund ltd partnership and matchable expenditures

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

Principal Issues:

1. Will the mutual fund limited partnership be subject to extended grandfathering from the application of draft 18.1 of the Act?

2. Will the XXXXXXXXXX changes to increase the distribution fees receivable by the Partnership taint the grandfathering under 1(b) of the XXXXXXXXXX Annex?

Position:

1. Yes.

2. No. They will still be grandfathered under 1(b).

Reasons:

1. Consistent with News Release 96-099 issued by Dept. of Finance on December 19, 1996. They came in for a ruling on XXXXXXXXXX.

2. XXXXXXXXXX

XXXXXXXXXX							970034
XXXXXXXXXX

Attention: XXXXXXXXXX

XXXXXXXXXX, 1997

Dear Sirs:

Re: XXXXXXXXXX

This is in reply to your letter dated XXXXXXXXXX, as amended by your letters dated XXXXXXXXXX, wherein you requested advance income tax rulings on behalf of the above-named taxpayers and the Partnership in connection with the proposed transactions described below.

Our understanding of the relevant facts, proposed transactions and the purpose of the proposed transactions is as follows:

FACTS

XXXXXXXXXX

Both corporations will file their income tax returns at the XXXXXXXXXX Tax Services Office and are "private corporations" in accordance with the definition of the term under subsection 89(1) of the Income Tax Act (Canada) (the "Act").

Each of the XXXXXXXXXX (collectively the "Funds") is an open ended mutual fund. Each of the Funds qualifies as a unit trust and a mutual fund trust within the meaning of subsections 108(2) and 132(6) of the Act, respectively. In addition, both the XXXXXXXXXX are "registered investments" within the meaning of section 204.4 of the Act.

XXXXXXXXXX

XXXXXXXXXX

XXXXXXXXXX

The capital of each of the Funds is divided into units ("Units") which are offered for sale to the public at a price (the "Unit Price") equal to the Net Asset Value (as described below in paragraph 7) per Unit as of the date of purchase. Units are also redeemable by the holders thereof at a price (the "Redemption Price") equal to the Net Asset Value per Unit as of the date of redemption.

The Trust Deeds of the Funds provide for the method of valuing the assets of the Funds and for the computation of the net asset value ("Net Asset Value") of the Funds, which is in turn used to calculate the Net Asset Value per Unit. In determining the Net Asset Value of a Fund, assets of the Fund are valued at market value determined by the Manager as being the most recent value established on the market at which the asset held by the Fund trades. Liabilities of the Fund are deducted from the aggregate asset value so determined. In general, the Net Asset Value per Unit is obtained by dividing the Net Asset Value of the Fund by the number of Units of the Fund outstanding.

Since the date of the Funds' formation, Units have been sold at a cost to the purchaser (the "Unit Price") equal to the aggregate Net Asset Value per Unit of all Units purchased plus a sales commission that is paid by the purchaser to the sales agent who sold the Units. The amount of the sales commission is negotiable but in no event may the sales commission exceed XXXXXXXXXX% of the Unit Price. Accordingly, the aggregate cost to the purchaser (the "Purchase Amount") equals the aggregate of the Unit Price and the negotiated sales commission.

XXXXXXXXXX is a "private corporation" in accordance with the definition of the term under subsection 89(1) of the Act and is a diversified financial services organization which provides, through its subsidiaries, management, administrative, marketing and distribution services.

Pursuant to the Trust Deeds governing each of the Funds, XXXXXXXXXX was appointed manager of each of the Funds. As manager of a Fund, XXXXXXXXXX is responsible for the management and administration of the Fund, including arranging the distribution of the Units and subcontracting the sale of Units of the Fund to persons who are registered under the securities legislation of the applicable jurisdictions to sell such Units.

In consideration of the management services provided by XXXXXXXXXX, the Funds pay management fees calculated as a percentage of the Net Asset Value of the Funds. The management fee for each Fund is paid monthly by the respective Funds. XXXXXXXXXX pays portfolio management fees to persons engaged to provide investment portfolio management advice to the Funds.

The Partnership was formed as a limited partnership under the XXXXXXXXXX by filing under the XXXXXXXXXX a declaration of partnership on XXXXXXXXXX with XXXXXXXXXX as general partner ("General Partner"), and XXXXXXXXXX as the initial limited partner, of the Partnership.

To the best of your knowledge and that of the taxpayers involved, none of the issues involved in this ruling are being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed, and none of the issues are under appeal or objection.

PROPOSED TRANSACTIONS

Units of the Funds are offered for sale on a continuous basis by registered dealers selling through the Manager or by other distribution agents appointed by the Manager. All such sales are subject to the prior approval of the Manager. Pursuant to a simplified prospectus and annual information form of the Funds, Units of the Funds will be offered for sale to the public under XXXXXXXXXX.

XXXXXXXXXX

XXXXXXXXXX

XXXXXXXXXX

If Units are Redeemed During Deferred Sales Charge
the Following Period after as a Percentage of
Date of Original Purchase or Original Unit Price
Deemed Original Purchase

XXXXXXXXXX

XXXXXXXXXX

XXXXXXXXXX

The following rules will govern the calculation of the Deferred Sales Charges levied against an investor on the redemption of Deferred Sales Charge Units:

XXXXXXXXXX

An investor may transfer all or any part of his Units between Funds if those Units were purchased under the same purchase option. A negotiable commission, which may not exceed XXXXXXXXXX% of the value of the Units exchanged, may be charged by the investor's dealer, regardless of the purchase option selected by an investor.

The Partnership will enter into an agreement (the "Distribution Agreement") with the Manager, whereby the Manager will grant to the Partnership the exclusive right to arrange for the distribution of Deferred Sales Charge Units of the Funds through registered dealers, in each of the provinces of XXXXXXXXXX. The Distribution Agreement will not provide any entitlement to the Partnership to distribute units of funds other than the Funds, noted above in paragraph 2. The period in which such distribution will be made (the "Distribution Period") shall commence on or after the date of this letter, and shall end on XXXXXXXXXX, or shall end on such earlier date on which the Partnership ceases to have cash available from (i) the proceeds of the offering of Partnership Units as described below in paragraph 25, (ii) amounts borrowed, and (iii) fee and investment income. Under the Distribution Agreement, the Partnership will be responsible for paying sales commissions payable to registered dealers in respect of the sale of Deferred Sales Charge Units distributed by the Partnership ("Sales Commissions"). No portion of these Sales Commissions will be (i) prepaid, (ii) paid prior to the date of this letter, or (iii) paid after XXXXXXXXXX, and the amount of the Sales Commissions will not exceed XXXXXXXXXX% of the Unit Price of Deferred Sales Charge Units sold. The Partnership will covenant in the Distribution Agreement not to incur expenditures, as contemplated in the Department of Finance Press Release 96-099 dated December 19, 1996, in excess of $XXXXXXXXXX. XXXXXXXXXX, as the manager of the Funds, will also undertake that no more than $XXXXXXXXXX will be paid in respect of sales commissions on units of the Funds distributed on or prior to XXXXXXXXXX. Notwithstanding these undertakings, note that the maximum Offering Amount, as described below in paragraph 25, is $XXXXXXXXXX. Only an amount equal to the Offering Amount will be used to incur expenditures, including the payment of Sales Commissions, as explained elsewhere in this letter.

In return for arranging for the distribution of Deferred Sales Charge Units and paying the Sales Commissions in respect thereof, the Partnership will receive a distribution fee, payable quarterly at an annual rate calculated as a percentage of the average daily Net Asset Value per Unit of the outstanding Deferred Sales Charge Units distributed by the Partnership. Pursuant to the terms of the Distribution Agreement, the distribution fee will vary between XXXXXXXXXX%, depending on the value of the Sales Commissions funded by the Partnership. The distribution fee represents a portion of the fee payable to XXXXXXXXXX by each of the Funds. Pursuant to the Distribution Agreement, XXXXXXXXXX will unconditionally and irrevocably assign and transfer such portion of its fee to the Partnership. The distribution fee will be payable to the Partnership commencing XXXXXXXXXX and, subject to earlier termination of the Partnership, will continue thereafter until XXXXXXXXXX. Notwithstanding the above, the Partnership will accrue a proportionate amount of distribution fee income in respect of its fiscal year ending XXXXXXXXXX, and will report such income for income tax purposes. The amount to be accrued by the Partnership will be calculated in accordance with generally accepted accounting principles.

In addition, the Partnership will be entitled to receive any Deferred Sales Charges paid upon the redemption of Deferred Sales Charge Units. The amount of such Deferred Sales Charges is payable to the Partnership on a quarterly basis commencing with the first quarter following the date of this letter.

A limited partnership agreement (the "Partnership Agreement") will be entered into between the General Partner of the Partnership and the initial limited partner which has contributed $XXXXXXXXXX to the capital of the Partnership for one limited partnership unit ("Partnership Unit") in the Partnership. Upon subscription of a Partnership Unit under the offering described in paragraphs 24 and 25 below, the initial limited partner's Partnership Unit shall be redeemed and the capital contribution made in respect thereof shall be returned.

Pursuant to a prospectus to be prepared and filed under the provisions of the XXXXXXXXXX, the Partnership will offer Partnership Units to the public in the Provinces of XXXXXXXXXX. An investor will become a "Limited Partner" of the Partnership upon acceptance, by the General Partner, of the investor's subscription for Partnership Units and the inclusion in the Partnership's books and records of the relevant information in respect of the investor.

The offering will consist of a minimum of XXXXXXXXXX Partnership Units and a maximum of XXXXXXXXXX Partnership Units at a price of $XXXXXXXXXX per Partnership Unit (i.e. the amount raised pursuant to the offering is hereinafter referred to as the "Offering Amount" and the maximum amount to be raised from the offering will be $XXXXXXXXXX). Partnership Units will be offered for sale only to persons resident in Canada. It is expected that the first closing of the offering of the Partnership Units will take place on or about XXXXXXXXXX and subsequent closings will occur no later than XXXXXXXXXX. The subscription price for Partnership Units will be payable in full in one instalment at the time of closing of the particular offering.

The Partnership will use the Offering Amount to pay to the Agent, as described in paragraph 27 below, a commission, expenses incurred in relation to the offering, Sales Commissions on Deferred Sales Charge Units, other operating expenses and to repay amounts borrowed and expenses related to such borrowings.

The Partnership has entered into an agreement with XXXXXXXXXX (the "Agent") pursuant to which the Agent, and its subagents, will distribute Partnership Units in XXXXXXXXXX, on a best efforts basis. The Partnership will pay to the Agent a commission of XXXXXXXXXX% of the Offering Amount in respect of all Partnership Units sold. No Partnership Units will be issued prior to the date of this ruling letter, although subscriptions for Partnership Units may be solicited, conditional upon the rulings requested being obtained.

Offering expenses of approximately $XXXXXXXXXX, to be incurred in connection with issuing or selling Partnership Units, will be paid by the Partnership. Such expenses will include advertising and marketing costs, legal and accounting costs related to the offering and the costs of preparing and printing prospectuses.

The Partnership Agreement provides that the General Partner will be entitled to XXXXXXXXXX% of the net income or loss of the Partnership and that XXXXXXXXXX% of such net income or loss will be allocated among Limited Partners of record at the end of each fiscal year in proportion to the number of Partnership Units held by each of them.

Pursuant to the Partnership Agreement, the general partner of the Partnership will have exclusive authority to manage the business and affairs of the Partnership and to make all decisions regarding the business of the Partnership.

Under the Partnership Agreement, any portion of the Limited Partners' capital contributions received by the Partnership that has not been expended on or prior to XXXXXXXXXX will be returned to the Limited Partners on or prior to XXXXXXXXXX, in proportion to the number of Partnership Units owned by each of them.

Commencing in XXXXXXXXXX, the Partnership shall make quarterly cash distributions ("Cash Distributions"), as defined below, to the General Partner and Limited Partners of record, in proportion to the number of Partnership Units held by each of them, for each calendar quarter or such other period as may be determined (the "Distributable Period").

Cash Distributions means the amount by which cash receipts by the Partnership in respect of the Distributable Period and the amount of any reserves retained at the end of such previous period, if any, exceed the expenses of the Partnership for the Distributable Period, and any reserves established by the General partner for the ensuing Distributable Period. In the case of a Distributable Period ending on XXXXXXXXXX, such Cash Distributions will be made within XXXXXXXXXX days of the end of such Distributable Period and for other Distributable Periods, Cash Distributions will be made within XXXXXXXXXX days of the end of the particular Distributable Period.

The Partnership will be terminated and the procedures for dissolution will be commenced upon the first occurring of the following events or dates:

(a) XXXXXXXXXX;

(b) the first day after XXXXXXXXXX on which there remains outstanding no Deferred Sales Charge Units in respect of which the Partnership is entitled to receive distribution fees;

(c) the removal or deemed removal of the General Partner unless the General Partner is replaced in accordance with the provisions of the Partnership Agreement; or

(d) the date upon which an extraordinary resolution is passed to dissolve the Partnership.

The General Partner has full authority, for and on behalf of and in the name of the Partnership, to borrow funds from time to time from financial institutions selected by the General Partner or from XXXXXXXXXX or its affiliates, including the General Partner, but only to pay operating expenses of the Partnership, including Sales Commissions and the cost of issuing Partnership Units. All such indebtedness of the Partnership will be repaid on or before XXXXXXXXXX, and there will be no borrowings by the Partnership subsequent to such date. The rate of interest and any other expenses related to such borrowings shall not exceed that which the Manager pays in relation to borrowings from its principal lenders on loans to finance the Partnership plus XXXXXXXXXX% per annum, and shall never exceed that which the Partnership could obtain from a Canadian chartered bank with respect to similar borrowings.

On behalf of the Partnership, the General Partner will enter into an administrative services agreement with its affiliate, XXXXXXXXXX. XXXXXXXXXX is a subsidiary wholly-owned corporation of XXXXXXXXXX and is a "private corporation" in accordance with the definition of the term under subsection 89(1) of the Act. XXXXXXXXXX will provide administrative services to the Partnership which will include:

(a)maintaining financial accounts in connection with the business of the Partnership;

(b)preparing and filing all necessary reports and filings required by applicable corporate, partnership and securities legislation;

(c)paying distributions to Limited Partners;

(d)arranging for the payment of Sales Commissions to dealers in connection with the distribution of Units by the Partnership; and

(e)providing all other general day-to-day activities as may be required for the purpose of maintaining the business and operation of the Partnership.

Commencing XXXXXXXXXX, XXXXXXXXXX is to be reimbursed by the Partnership for all expenses incurred by it on behalf of the Partnership and to receive an annual fee equal to XXXXXXXXXX% of ongoing expenses of the Partnership, other than interest or other expenses related to borrowings by the Partnership and Sales Commissions payable by the Partnership. The aggregate of all such fees and expenses to be reimbursed for the period ending XXXXXXXXXX is limited to $XXXXXXXXXX which amount may increase by XXXXXXXXXX% per year thereafter. XXXXXXXXXX may waive all or a portion of its fee upon the request of the Partnership.

The Partnership's annual financial statements, as reported on by the auditors, will account for Sales Commissions paid on unredeemed Deferred Sales Charge Units by amortizing the Sales Commissions based on revenue over a XXXXXXXXXX year period.

The Partnership Units will be a tax shelter within the meaning assigned by subsection 237.1(1) of the Act. The General Partner will obtain an identification number in respect of the Partnership pursuant to subsection 237.1(2) of the Act. The General Partner will file annual tax shelter information returns and provide copies to the Limited Partners pursuant to subsection 237.1(7) of the Act.

The fiscal period of the Partnership will end on XXXXXXXXXX.

PURPOSE OF THE PROPOSED TRANSACTIONS

The purpose of the Partnership is to pay the Sales Commissions on sales of Deferred Sales Charge Units of the Funds, to facilitate the sale of such Deferred Sales Charge Units to investors in the Funds and to allow such investors to earn income based on distribution fees earned by the Partnership and Deferred Sales Charges payable to the Partnership on the redemption of Deferred Sales Charge Units, including such Units issued upon the automatic reinvestment of distributions on Deferred Sales Charge Units of the Funds.

RULINGS GIVEN

Provided that the above statements of fact and proposed transactions are accurate and constitute complete disclosure of all of the relevant facts and proposed transactions, the proposed transactions are carried out as herein described and the Partnership is a partnership at law, our rulings in respect of the proposed transactions are as follows:

A.The Sales Commissions described in paragraph 21 above, incurred by the Partnership on or after the date of this advance income tax ruling and during the Distribution Period, with respect to the Deferred Sales Charge Units for which it arranges distribution, will be amortized and deductible over three fiscal periods by the Partnership in computing its income or loss under the Act in the following manner:

-33 1/3% for the fiscal period in which the Sales Commissions are incurred; and

-33 1/3% for each of the subsequent two fiscal periods after the fiscal period in which the Sales Commissions are incurred.

B.Provided they are reasonable, expenses, as described in paragraphs 26 to 28 above, incurred in a particular fiscal period or preceding fiscal period by the Partnership in the course of issuing or selling Partnership Units pursuant to the public offering, described in paragraph 24 and 25 above, will, to the extent of the lesser of:

(i) that proportion of 20% of the expenses that the number of days in the fiscal period is of 365; and

(ii) the amount, if any, by which the expenses exceeds the aggregate of all amounts each of which is an amount deductible by the Partnership in respect of these expenses in computing its income for a preceding fiscal period,

be deductible in computing the income or loss of the Partnership for the particular fiscal period pursuant to paragraph 20(1)(e) of the Act.

C.The Partnership will be entitled to deduct, in computing its income or loss for a fiscal period for income tax purposes, interest of a reasonable amount paid or payable in the period (depending on the method to be regularly followed by the Partnership in computing its income) on money borrowed by the Partnership to fund the payment of Sales Commissions and other expenses, as contemplated by paragraph 34 above, pursuant to subparagraph 20(1)(c)(i) of the Act, provided the interest is paid or payable pursuant to a legal obligation to pay.

D.A limited partner who owns Partnership Units at the end of a fiscal period of the Partnership will, subject to the provisions of subsection 96(2.1) and subsection 237.1(6) of the Act, be entitled to deduct the amount of losses of the Partnership for the fiscal period allocated to the Limited Partner in accordance with the Partnership Agreement, as described in paragraph 29 above, in computing the Limited Partner's income or loss for income tax purposes for the taxation year in which that fiscal period ends.

E.The provisions of paragraph 96(2.2)(d) of the Act will not apply to reduce a Limited Partner's "at-risk" amount in respect of the Partnership at the end of a fiscal period thereof, by reason of:

(i) the Partnership's entitlement to the fees and charges pursuant to the Distribution Agreement as described in paragraph 22 above;

(ii) the limitation of the amount payable by the Partnership to XXXXXXXXXX for its services under the administrative services agreement, as described in paragraph 35 above; and

(iii)the Partnership Agreement providing for the distribution to Limited Partners by the General Partner of any amount of net proceeds of the offering of Partnership Units remaining unexpended by the Partnership on XXXXXXXXXX, as described under paragraph 31, as such distribution will reduce the adjusted cost base of the Limited Partner's Partnership Units by virtue of subparagraph 53(2)(c)(v) of the Act.

F.The distribution fee payable by XXXXXXXXXX to the Partnership under the Distribution Agreement, as described in paragraph 22 above, will be deductible by XXXXXXXXXX in computing its income for its taxation year in which such fees are incurred, provided that such distribution fee is reasonable and incurred for the purpose of gaining or producing income from a business or property with a reasonable expectation of profit.

These rulings are given subject to the general limitations and qualifications set forth in Information Circular 70-6R3 issued by Revenue Canada, Taxation on December 30, 1996, and are binding provided the last closing of the offering of Partnership Units described in paragraph 25 is made by XXXXXXXXXX. These rulings are based on the Act and Regulations to the Act in force as of the date of this letter, without taking into account any future amendments thereto, whether currently proposed or not. Except as expressly stated, our rulings do not imply acceptance, approval or confirmation of any income tax implications of the facts or proposed transactions. In particular, nothing in this letter should be interpreted as confirming, either expressly or implicitly: (a) the reasonableness of any of the expenses of the Partnership; and (b) the existence of a reasonable expectation of profit of the Partnership or any partner of the Partnership. Also, these rulings are not to be construed as confirming, in any way, the implications of the goods and services tax in respect of any of the proposed transactions.

OPINIONS

If the provisions of draft section 18.1 are enacted as proposed in the Notice of Ways and Means Motion tabled on November 18, 1996 by the Secretary of State (Finance) and the Department of Finance Press Release 96-099 dated December 19, 1996, it is our opinion that

(a)the Sales Commissions deductible by the Partnership in accordance with ruling A above will, notwithstanding proposed section 18.1 of the Act, continue to be amortized and deductible by the Partnership in computing its income or loss for its fiscal period as set out in ruling A above provided such Sales Commissions (as well as any incurred after XXXXXXXXXX and prior to the date of this advance ruling) do not exceed $XXXXXXXXXX. Should the aggregate exceed $XXXXXXXXXX, such Sales Commissions will be deductible by the Partnership only as and to the extent provided in proposed subsection 18.1(4); and

(b)except as provided in (a) above and excluding XXXXXXXXXX, no transitional relief from the application of proposed section 18.1 will be available with respect to an expenditure described in proposed section 18.1 incurred after November 17, 1996 in respect of the distribution of shares of a mutual fund corporation or units of a mutual fund trust administered by XXXXXXXXXX or any person related thereto.

Notwithstanding the rulings given in this letter, if the provisions of proposed section 143.2 are enacted as proposed in Bill C-69 in the form which received first reading by the House of Commons on December 2, 1996, it is our opinion that

(a)the amount of any "expenditures" made by the Partnership, including, but not limited to, Sales Commissions and the issuance expenditures referred to in rulings A and B above, will be reduced by the total of

(i)the "limited-recourse amounts" of

(A)the Partnership, and

(B)all taxpayers not dealing at arm's length with the Partnership

that can reasonably be considered to relate to the particular expenditures,

(ii)the Partnership's "at-risk adjustment" in respect of the particular expenditures, and

(iii)the limited-recourse amounts and at-risk adjustments of each taxpayer who deals at arm's length with and holds an interest in the Partnership that can reasonably be considered to relate to the particular expenditures;

(b)if any Limited Partner has limited-recourse amounts that can reasonably be considered to relate to the acquisition of his Partnership Units:

(i)proposed subsection 143.2(6) (not subparagraph 53(2)(c)(i.3)) of the Act will apply to reduce that Limited Partner's cost of the Partnership Units, and

(ii)the expenditures made by the Partnership will also be considered to relate to those limited-recourse amounts and will be reduced by the total of such limited-recourse amounts;

(c)indebtedness of the Partnership, referred to in paragraph 34 above, will, pursuant to proposed subsection 143.2(8) of the Act but subject to proposed subsection 143.2(11), be considered to be a limited-recourse amount so as to reduce the amount of any expenditure of the Partnership that would otherwise be deductible in computing its income; if a repayment of such indebtedness is not part of a series of loans or other indebtedness and repayments by the Partnership, the repayment at any time by the Partnership of such indebtedness will, pursuant to proposed subsection 143.2(10) of the Act, result in the said expenditure being deemed to have been made or incurred at that time, for purposes of the Act including proposed section 18.1, to the extent of the amount of the repayment; and

(d)proposed subsection 143.2(6) of the Act will not be applied to reduce the amount of a Limited Partner's expenditure to acquire Units of the Partnership by reason of

(i)the Partnership Agreement providing for the distribution of capital by the Partnership to Limited Partners in certain cases such as described in paragraphs 31 and 32 above, or

(ii)the Partnership's entitlement to the distribution fees and charges payable under the Distribution Agreement, as described in paragraph 22 above.

The terms "expenditure", "limited-recourse amount" and "at-risk adjustment" as used above have the meanings assigned thereto by proposed section 143.2 of the Act.

The opinions expressed above are provided in accordance with paragraph 20 of Information Circular 70-6R3. Such opinions do not constitute advance income tax rulings and are not binding on the Department.

As stated in paragraph 7 of Information Circular 70-6R3, binding rulings are not provided for transactions that are not seriously contemplated and are hypothetical in nature. Accordingly, no rulings have been provided in respect of transactions relating to any subsequent offering(s) that may occur, other than the offering described above in paragraphs 24 and 25, nor with respect to the right to distribute other funds, not listed above in paragraph 2.

Yours truly,

for Director
Resources, Partnerships and
Trusts Division
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch