2000 Income Tax Severed Letter 2000-0050431 - RETIREMENT BENEFITS

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: Whether changes to the facts and proposed transactions will affect the ruling given.

Position: No.

Reasons: The changes have no impact on the ruling given.

XXXXXXXXXX 2000-005043

Attention: XXXXXXXXXX

XXXXXXXXXX, 2000

Dear XXXXXXXXXX:

Re: Supplemental Advance Income Tax Ruling Request
XXXXXXXXXX

We are replying to your letter of XXXXXXXXXX, in which you informed us of changes to the facts and proposed transactions in the Advance Income Tax Ruling (the "Ruling") issued by us on XXXXXXXXXX, 2000. Terms defined in the Ruling otherwise have the same meaning.

Paragraph 16 of the Ruling is amended as follows:

Approximately XXXXXXXXXX Retirees were entitled to the Retiree Benefits as retired employees (their spouses and dependent children) of the Taxpayer's Canadian operations (the "Canadian Retirees"). Approximately XXXXXXXXXX Retirees were entitled to the Retiree Benefits as retired employees (their spouses and dependent children) of the Taxpayer's XXXXXXXXXX

The fourth sentence of paragraph 30 of the Ruling is amended as follows:

The present value of each Retiree's foregone Medical Benefit was calculated as the expected future payout for each individual using (1) with respect to the Canadian Retirees, an average annual health care cost determined on the basis of past claims experience of the Canadian Retirees as a group, and (2) with respect to the XXXXXXXXXX, an annual claims cost estimate which differentiates between those eligible for XXXXXXXXXX and those not eligible.

We confirm that the above changes will not, in itself, affect the Ruling previously given provided that the proposed transactions are commenced before XXXXXXXXXX.

Yours truly,

XXXXXXXXXX
for Director
Business and Publications Division
Income Tax Rulings Directorate

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