2003 Income Tax Severed Letter 2002-0176711 - SUPPLEMENTAL RULING

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:

1. Minor change in facts re ruling 2002-014913: The phrase "... minus the amount of benefits paid from the Registered Pension Plan" in paragraph 10 of the ruling was removed.

2. Extension of time

Position: 1. No effect on ruling 2. Yes

Reasons:

1. See above.

2. Reasonable under circumstances

XXXXXXXXXX 2002-017671

XXXXXXXXXX, 2003

Dear XXXXXXXXXX:

Re: XXXXXXXXXX (the "Organization")
Advance Income Tax Ruling 2002-014913, dated XXXXXXXXXX, 2002

This is in reply to your letter of XXXXXXXXXX and several telephone calls (XXXXXXXXXX) in which you advise us of a minor change to paragraph 10 of the facts contained in the above Advance Income Tax Ruling.

You indicated that the phrase "... minus the amount of benefits paid from the Registered Pension Plan" should be removed. Consequently, paragraph 10 would then read as follows:

10. The benefit formula under the Supplementary Pension Plan is XXXXXXXXXX% of the XXXXXXXXXX-year average pensionable remuneration multiplied by the years of service. Under the subsection XXXXXXXXXX of the Supplementary Pension Plan, a member who elects to participate is entitled to receive an annual pension payable monthly during the lifetime of the member.

You have also requested an extension of time until XXXXXXXXXX.

We hereby confirm that, taking into account the change in the wording of paragraph 10 as set out above, the rulings given in advance income tax ruling 2002-014913 will continue to be binding on the Canada Customs and Revenue Agency, subject to the conditions set out therein and in accordance with the practice outlined in Information Circular 70-6R5, dated May 17, 2002, provided that the proposed transactions are completed by XXXXXXXXXX.

Yours truly,

XXXXXXXXXX
for Director
Financial Industries Division
Income Tax Rulings Directorate
Policy and Legislation Branch