2002 Ruling 2002-0159233 - RETIRING ALLOWANCE

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 CCRA.

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

Principal Issues:

Will amendments to file 2001-014028 affect the rulings given?

Position: No.

Reasons:

The amendments do not affect the application of the law.

XXXXXXXXXX
				2002-015923
XXXXXXXXXX, 2002							

Dear XXXXXXXXXX:

Re: Advance Income Tax Ruling
XXXXXXXXXX

This is in reply to your letter of XXXXXXXXXX, and is supplemental to our advance income tax ruling number 2002-014028 dated XXXXXXXXXX, 2002 (the "Ruling").

The Ruling is hereby amended as follows:

1. The Term "Closing Date" defined in the Ruling is amended to read:

"(c) "Closing Date" means: XXXXXXXXXX or such other later date as the Employer and the Purchaser may agree;"

2. In subparagraphs 11(f), 15(f) and 16(h), the date "XXXXXXXXXX" shall be amended to "the Closing Date"; and

3. Paragraph 17, as referred to in paragraph 19, will be amended to add the following:

"The amount of the reimbursement to be paid by the Purchaser to the Employer will not be a 100% reimbursement. The amount to be reimbursed has been negotiated between the parties and is based on a formula set out in the Reimbursement Agreement between the Employer and the Purchaser, a draft copy of which has been provided."

We confirm that the Ruling remains binding on the Canada Customs and Revenue Agency subject to the same limitations and qualifications set out therein.

Yours truly,

XXXXXXXXXX
for Director
Financial Industries Division
Income Tax Rulings Directorate