2004 Ruling 2004-0075681R3 - Unfunded SERP; recognition of prior years service

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.

Principal Issues:

Will the arrangement be an SDA?

Position:

No.

Reasons:

The employees' remuneration is not specifically being reduced or deferred in order to obtain the added benefits under the SERP. Accordingly, the arrangement is not an SDA.

XXXXXXXXXX 							2004-007568

XXXXXXXXXX, 2004

Dear XXXXXXXXXX:

Re: Advance Income Tax Ruling - Supplemental Executive Retirement Plan
XXXXXXXXXX

This is in reply to your letter of XXXXXXXXXX, and your correspondence of XXXXXXXXXX, in respect of your request for the above-noted advance income tax ruling.

This letter is based solely on the facts and proposed transactions described below. The documentation submitted with your request does not form part of the facts and proposed transactions and any references thereto are provided solely for the convenience of the reader.

Definitions and Abbreviations

In this letter, the following terms have the meanings specified:

(a) "Act" means: the Income Tax Act, R.S.C. 1985 (5th Supp.) c.1, as amended to the date hereof;

(b) "CRA" means: the Canada Revenue Agency;

(c) "Corporation" means: XXXXXXXXXX

BIN: XXXXXXXXXX
XXXXXXXXXX Tax Services Office,
XXXXXXXXXX Tax Centre;

(d) "Executives" means: senior executive employees of the Corporation and the Corporation's subsidiaries and affiliates;

(e) "Member" means: an employee of a Participating Employer who is a member of the RPP;

(f) "Participant" means: an Executive that participates in the SERP including senior executives of the Corporation's subsidiaries and affiliates that were not eligible to participate in the SERP prior to XXXXXXXXXX;

(g) "Participating Employers" means: the Corporation and employers that are affiliated with the Corporation that participate in the RPP;

(h) "Regulations" means: The Income Tax Regulations;

(i) "RPP" means: the Corporation's registered pension plan with registration number XXXXXXXXXX;

(j) "SERP" means: The Corporation's Supplemental Executive Retirement Plan that was established on XXXXXXXXXX, to provide retirement benefits to senior executive officers of the Corporation in order to top-up pensions payable to them under the RPP;

(k) "SERP-A Plans" means: the pension plan for employees of Subsidiary-A and/or the pension plan for key executives of Subsidiary-A, as applicable; and

(l) "Subsidiary-A" means: XXXXXXXXXX.

In addition, in this letter:

(m) the term "registered pension plan" has the meaning assigned by subsection 248(1) of the Act, and the term "Year's Maximum Pensionable Earnings" (YMPE) has the meaning assigned by subsection 8500(1) of the Regulations.

Relevant Facts

Background

1. The Corporation is a XXXXXXXXXX corporation with its head office located in XXXXXXXXXX.

2. The Corporation and its predecessors maintained a single pension plan from XXXXXXXXXX until XXXXXXXXXX to provide retirement benefits to employees of the Corporation and its affiliates, and to their beneficiaries. XXXXXXXXXX. The Corporation also maintains other plans for the benefit of its employees. One of those plans is the SERP.

3. Effective XXXXXXXXXX, certain Executives of the Corporation joined the RPP and the SERP with respect to future services to be provided by the Executives to the Corporation.

4. The Corporation has paid annual bonuses to certain employees including one or more of the Executives.

The RPP

5. The pertinent provisions of the RPP, for the purposes of this ruling, are as follows:

(a) Eligibility for Membership

i. Every person who was a member of the Corporation's contributory pension plan or the Corporation's non-contributory pension plan on XXXXXXXXXX, continued to be a Member of the RPP on and after XXXXXXXXXX.

ii. On or after XXXXXXXXXX and before XXXXXXXXXX, each full-time and part-time employee (except casual employees) who was not a member of the contributory pension plan or a member of the non-contributory pension plan on XXXXXXXXXX, had to elect to become either a contributing Member of the RPP (a "Contributory Member") or a non-contributing Member of the RPP (a "Non-contributory Member") after XXXXXXXXXX months of continuous service and after attainment of age XXXXXXXXXX. Employees hired on or after XXXXXXXXXX may only join the RPP as Non-contributory Members after XXXXXXXXXX months of continuous service and after attainment of age XXXXXXXXXX.

(b) Contributions

i. Contributory Members of the RPP are required to contribute XXXXXXXXXX percent of their salary up to the YMPE of the Canada Pension Plan or the Quebec Pension Plan, plus XXXXXXXXXX percent of any salary in excess of the YMPE, with a maximum of $XXXXXXXXXX a year per Member. Contributory Members will contribute for a maximum of XXXXXXXXXX years. Non-contributory Members are not permitted to contribute.

ii. Participating Employers are required to make contributions to the RPP to meet the balance of the cost of the RPP as recommended by an actuary and subject to the requirements of the Pension Benefits Standards Act.

In general terms, a Member's "Contributory Credited Service" is service in respect of which the Member makes contributions; "Non-contributory Credited Service" is service in respect of which a Member does not make contributions; and, "Credited Service" is the total service as determined for the purposes of the RPP.

(c) Retirement Dates

i. "Normal Retirement Date" means the first day of the month coincident with or next following a Member's XXXXXXXXXX birthday. Normal retirement benefits begin on the last day of the month following the Normal Retirement Date of a Member.

ii. "Early Retirement Date" means the date on which a Member may retire early, and is a date within XXXXXXXXXX years of the Normal Retirement Date provided the Member has completed XXXXXXXXXX years of employment.

(d) The amount of retirement benefits payable for life at Normal Retirement Date is equal to the sum of the following:

i. In respect of a Contributory Member's Credited Service:

A. XXXXXXXXXX% of the Member's final average earnings (as described in (d)(iii) below) on such date multiplied by the Member's Contributory Credited Service, if any, accumulated to XXXXXXXXXX ;

B. XXXXXXXXXX% of the Member's final average earnings up to the final average YMPE on such date multiplied by the lesser of:

(1) that portion of the member's Contributory Credited Service accrued after XXXXXXXXXX; and

(2) XXXXXXXXXX years minus the Member's years of Contributory Credited Service, if any, accumulated to XXXXXXXXXX; and

C. XXXXXXXXXX % of the excess, if any, of the Member's final average earnings over the final average YMPE on such date multiplied by the lesser of:

(1) that portion of the Member's Contributory Credited Service accrued after XXXXXXXXXX; and

(2) XXXXXXXXXX years minus the Member's years of Contributory Credited Service, if any, accumulated to XXXXXXXXXX.

ii. In respect of a Non-contributory Member's Credited Service:

A. XXXXXXXXXX% of the Member's final average earnings on such date multiplied by the Member's Non-contributory Credited Service, if any, accumulated to XXXXXXXXXX;

B. XXXXXXXXXX% of the Member's final average earnings up to the final average YMPE on such date multiplied by the lesser of:

(1) that portion of the Member's Non-contributory Credited Service accrued after XXXXXXXXXX; and

(2) XXXXXXXXXX years minus the Member's years of Non-contributory Credited Service, if any, accumulated to XXXXXXXXXX; and

C. XXXXXXXXXX% of the excess, if any, of the Member's final average earnings over the final average YMPE on such date multiplied by the lesser of:

(1) that portion of the Member's Non-contributory Credited Service accrued after XXXXXXXXXX; and

(2) XXXXXXXXXX years minus the Member's years of Non-contributory Credited Service, if any, accumulated to XXXXXXXXXX.

iii. Final average earnings of a Member is generally the highest average annual salary of the Member for XXXXXXXXXX consecutive years during the last XXXXXXXXXX years of plan membership.

iv. If a Member has both Contributory and Non-contributory Credited Service and the total of the Member's Contributory and Non-contributory Credited Service exceeds XXXXXXXXXX years, the Member's pension will be calculated to reflect a maximum of XXXXXXXXXX years total Credited Service. The Credited Service will be appropriately allocated between the two provisions so as to provide the highest benefit to the Member.

v. The pension at early retirement is calculated using the same formula based on Contributory Credited Service and Non-contributory Credited Service and salaries up to the early retirement date and reduced by XXXXXXXXXX percent for each month by which the early retirement date precedes age XXXXXXXXXX. With a Participating Employer's consent, a reduction factor of XXXXXXXXXX percent for each month by which the early retirement date precedes age XXXXXXXXXX applies.

(e) Disability

During the period that a Contributory Member or Non-contributory Member qualifies for benefits under the Corporation's long-term disability plan, Credited Service for the purpose of the RPP continues to accrue. The employee contributions for Contributory Members are waived.

(f) Death Benefits

i. After retirement

In respect of Contributory Credited Service

The normal form of pension provides for monthly payments for the Member's life and, if married, for XXXXXXXXXX% of the benefit continuing to the surviving spouse. However, a married Member's benefit will be paid in the form of a joint and XXXXXXXXXX% survivor annuity unless this benefit is waived by the Member and the Member's spouse. The amount of pension payable to the Member in the form of a joint and XXXXXXXXXX% survivor annuity, would be reduced on an actuarial equivalent basis to provide this benefit.

Upon the death of an unmarried Member or upon the death of the spouse of a Member, a death benefit equal to the excess, if any, of the Member's contributions with interest at retirement over the pension payments made with respect to the Member is paid.

In respect of Non-contributory Credited Service

The normal form of pension provides for monthly payments for the Member's lifetime only. However, a married Member will be paid in the form of a joint and survivor annuity providing a XXXXXXXXXX% surviving spouse benefit unless this benefit is waived by the Member and the Member's spouse. The amount of pension payable to the Member will be reduced on an actuarial equivalent basis to provide for this benefit.

ii. Prior to retirement

Upon death prior to retirement, the following benefits are provided:

A. For service up to XXXXXXXXXX, a refund of the Member's contributions with interest, if any; and

B. For service from XXXXXXXXXX, the spouse of a Member who dies after completing XXXXXXXXXX years of service and prior to age XXXXXXXXXX will be entitled to a payment of the commuted value of the Member's pension and the spouse of a Member who dies after age XXXXXXXXXX will be entitled to receive a pension in the amount that would have been payable if the Member had retired immediately prior to death and then died. If a Member has no surviving spouse or has not completed XXXXXXXXXX years of service, a refund of the Member's contributions, if any with interest will be paid.

(g) Termination Benefits

i. For service up to XXXXXXXXXX :

A. before age XXXXXXXXXX and the completion of XXXXXXXXXX years of service, a Member is entitled to a refund of the member's required contributions, if any, with interest; and

B. after age XXXXXXXXXX and the completion of XXXXXXXXXX years of service, a Member is entitled to a refund of the Member's required contributions made before XXXXXXXXXX , if any, with interest, and a deferred pension payable from normal retirement date, calculated using the normal retirement pension formula based on Contributory Credited Service and Non-contributory Credited Service, as applicable, between XXXXXXXXXX.

ii. For service from XXXXXXXXXX :

A. before completion of XXXXXXXXXX years of service a Member is entitled to a refund of the Member's required contributions, if any, with interest; and

B. after completion of XXXXXXXXXX years of service a Member is entitled to a deferred pension payable from normal retirement date calculated using the normal retirement pension formula based on Contributory Credited Service and Non-contributory Credited Service, as applicable, from XXXXXXXXXX to the date of termination of employment.

(h) Excess employee contributions

Upon termination of employment, death or retirement, a Member with Contributory Credited Service will be credited with the excess, if any, of the amount of the Member's own contributions, with interest for service from XXXXXXXXXX, over XXXXXXXXXX% of the value of benefits otherwise payable for contributory service from XXXXXXXXXX. This excess contribution credit will be applied to increase the amount of pension or death benefit otherwise payable.

(i) Portability

The commuted value of a Member's deferred pension entitlement may be transferred to a locked-in registered retirement savings plan or another registered pension plan.

(j) Maximum pension

The maximum annual pension at retirement, or at termination of employment, under the RPP may not exceed the lesser of:

i. $XXXXXXXXXX in years prior to XXXXXXXXXX, $XXXXXXXXXX in XXXXXXXXXX and $XXXXXXXXXX after XXXXXXXXXX, times the number of years of total Credited Service not exceeding XXXXXXXXXX, or

ii. an amount that is the product of (A) XXXXXXXXXX percent of the average of the best XXXXXXXXXX years of earnings multiplied by (B) the number of years of total Credited Service not exceeding XXXXXXXXXX.

The SERP

6. The SERP is unfunded.

7. The pertinent provisions of the SERP for the purposes of this ruling, as they currently exist, are as follows:

(a) "Service", in relation to a Participant, means the Participant's years of continuous service with the Corporation and its affiliates (as defined in the XXXXXXXXXX) and includes:

i. pensionable service credited to the Participant at the time of hire, as provided under the RPP, and comparable service under the SERP-A Plans; and

ii. periods during which the Participant is in receipt of disability benefits from a short-term or long-term disability income continuance plan sponsored by the Corporation or Subsidiary-A. [XXXXXXXXXX of the SERP]

(b) "Non-contributory Service" of a Participant generally includes:

i. for a Participant who commenced participation prior to XXXXXXXXXX, the Participant's Non-contributory Credited Service with the Corporation for purposes of the RPP; and

ii. for a Participant who commences participation on or after XXXXXXXXXX, the Participant's:

A. Non-contributory Credited Service for purposes of the RPP,

B. credited service as defined in the SERP-A Plans, and

C. service, as determined by the Corporation, while a member of a retirement income plan of Subsidiary-A, other than the SERP-A Plans. [XXXXXXXXXX of the SERP]

(c) A senior executive officer or a senior vice president is eligible to participate in and to continue as a Participant in accordance with the terms of the SERP, as in effect on and after XXXXXXXXXX, if the individual is in active employment on or after XXXXXXXXXX and:

i. is designated, as a senior executive officer, upon the recommendation of the chief executive officer, to participate in the SERP and has not been excluded from further participation in accordance with 7(h) or (i) below; or

ii. is designated, as a senior vice president, by the chief executive officer to participate in the SERP and has not been excluded from further participation in accordance with 7(h) or 7(i) below. [XXXXXXXXXX of the SERP]

(d) The designation of an individual may provide that benefits payable under the SERP are to be determined with respect to only a specified portion of an employee's Service, as recommended by the chief executive officer. [XXXXXXXXXX of the SERP]

(e) For designations on or after XXXXXXXXXX, if the individual has Service with a former employer which is recognized as pensionable service under the RPP, or has comparable service under the SERP-A Plans, such service shall be excluded from consideration for purposes of the SERP, unless expressly included upon the individual's designation. [XXXXXXXXXX of the SERP]

(f) Notwithstanding 7(e) above, after the designation of an individual, a portion of a Participant's Service not recognised at the time of the individual's designation may be recognized as Service. [XXXXXXXXXX of the SERP]

(g) With respect to any period of Service, which is excluded from consideration for the purposes of the SERP, an employee may be entitled to benefits under the Corporation's provisions to provide top-up pensions to employees, other than senior executive officers. [XXXXXXXXXX of the SERP]

(h) An individual who has been designated to participate under the SERP on or after XXXXXXXXXX, may subsequently be excluded from further participation in the SERP, and such individual shall be entitled to the benefits accrued under the SERP to the date of exclusion, based on the individual's Contributory Service, Non-contributory Service, base salary and bonuses up to the date of exclusion, paid as some form of compensation or retirement value, as determined appropriate by the Corporation. [XXXXXXXXXX of the SERP]

(i) Where a senior executive officer participated under the terms of the SERP as it read prior to XXXXXXXXXX, but has not been designated in accordance with 7(c) above, such senior executive officer shall be entitled to the benefits accrued under the SERP as it read prior to XXXXXXXXXX, to the date of exclusion, based on the senior executive officer's Contributory Service, Non-contributory Service, base salary and bonuses up to the date of exclusion, paid as some form of compensation or retirement value, as determined appropriate by the Corporation. [XXXXXXXXXX of the SERP]

(j) "Retirement" for the purposes of the SERP means any termination of employment from the Corporation or Subsidiary-A on or after an individual's "Retirement Eligibility Date", which is the day on which an individual has completed at least XXXXXXXXXX years of Service; and

i. is or was employed, at age XXXXXXXXXX, as a senior executive officer or a senior vice president in an active full-time capacity; or

ii. is hired as, or promoted to, after age XXXXXXXXXX, a senior executive officer or senior vice president in an active full-time capacity. [XXXXXXXXXX of the SERP]

(k) For senior executive members, the SERP provides a pension of XXXXXXXXXX% of final average earnings for each year of Service (not in excess of XXXXXXXXXX years) less benefits payable from the RPP (less Canada/Quebec Pension Plan benefits), the SERP-A Plans and any retirement income plan of Subsidiary-A, as determined by the Corporation. [XXXXXXXXXX of the SERP]

(l) For senior vice presidents, the SERP provides a pension of XXXXXXXXXX% of final average earnings for each year of Contributory Service and XXXXXXXXXX% of Non-contributory Service (in total, not in excess of XXXXXXXXXX years), less benefits payable from the RPP (less Canada/Quebec Pension Plan benefits), the SERP-A Plans and any retirement income plan of Subsidiary-A, as determined by the Corporation. [XXXXXXXXXX of the SERP]

(m) If an individual retires and begins to receive benefits under the SERP prior to the 1st day of the month in which the individual attains age XXXXXXXXXX, (the individual's "Unreduced Retirement Date") the benefits payable under the SERP will be reduced by XXXXXXXXXX% for each year and part thereof (completed months to be computed as twelfths of a year) in which the individual's Retirement precedes the Unreduced Retirement Date. [XXXXXXXXXX of the SERP]

(n) Deferred allowances and death benefits similar to those payable under the RPP are also payable under the SERP. [XXXXXXXXXX of the SERP]

(o) If an individual's Service with the Corporation or Subsidiary-A is terminated for cause at any time, regardless of whether or not the Participant is entitled to retire, the Participant shall not be eligible to receive then, or at any time thereafter, any benefits under the SERP. [XXXXXXXXXX of the SERP]

(p) Final average earnings are determined as the average of the highest consecutive XXXXXXXXXX years salary plus the average of the highest XXXXXXXXXX years bonus in the last XXXXXXXXXX years of membership, subject to specified maximum earnings limits. [XXXXXXXXXX of the SERP]

(q) In the event that an individual transfers from employment with the Corporation or Subsidiary-A to a wholly-owned subsidiary corporation of the Corporation, and the transfer is specifically designated for the purpose of the SERP, the individual's benefits under the SERP shall be determined at the individual's subsequent Retirement from employment with such subsidiary. Upon the subsequent Retirement, benefits payable under the SERP to, or in respect of, an individual will be calculated in accordance with the provisions of the SERP as it is constituted at the date of such Retirement and based upon the individual's:

i. Contributory Service and Non-Contributory Service to the date of transfer, and

ii. base salary and bonuses for years of Service before and after the date of transfer.

(r) For greater certainty, where an individual transfers from employment with the Corporation or Subsidiary-A to a wholly-owned subsidiary corporation of the Corporation pursuant to 7(q) above:

i. the requirement of XXXXXXXXXX years of Service in the definition of "Retirement Eligibility Date" as described in 7(j) above, shall be deemed to be satisfied if the individual has completed at least XXXXXXXXXX years of continuous service with the Corporation or Subsidiary-A and such corporation, and

ii. the age XXXXXXXXXX requirements in the definition of "Retirement Eligibility Date" shall be deemed to be satisfied if:

A. the individual is continuously employed in an active full-time capacity with such corporation until age XXXXXXXXXX and subsequently retires; and

B. such corporation continuously qualifies as a wholly-owned subsidiary corporation of the Corporation until such retirement date. [XXXXXXXXXX of the SERP]

(s) Benefits will be payable under the terms of the SERP in consideration of the individual being available from time to time to provide XXXXXXXXXX services to the Corporation or Subsidiary-A. The individual shall not during the term of the SERP or at any time, while receiving payment of any benefits, provide XXXXXXXXXX services or advice on matters substantially similar to the services such Participant has provided to the Corporation or Subsidiary-A, either individually, in partnership or in conjunction with any person or persons, firm, association, syndicate, corporate or other business entity, as member, agent, employee, significant shareholder, guarantor, or in any other manner whatsoever, directly or indirectly, to any other person or persons, firm, association, syndicate, corporation or any other business entity which engages in activities substantially similar to and in direct competition with the Corporation or one of its affiliates and whose business is carried on in Canada or in any province of Canada or in any area or state of the United States of America. Where the individual engages in such activity the individual shall immediately cease to be entitled to any future payments of any benefits. The Corporation and the individual will contractually agree upon these provisions for non-competition with the Corporation or Subsidiary-A. [XXXXXXXXXX of the SERP]

(t) The remaining relevant provisions of the SERP are, in general, the same as, or similar to, the comparable provisions of the RPP as described above.

Proposed Transactions

8. The provisions of the SERP described in 7(h) will be amended to provide that a senior executive officer shall be entitled to the benefits accrued under the SERP to the date of exclusion, based on the senior executive officer 's Contributory Service, Non-contributory Service, base salary and bonus up to the date of exclusion, paid upon the senior executive officer's Retirement, termination of employment, or death.

9. The provisions of the SERP described in 7(i) will be amended to provide that, where a senior executive officer participated under the terms of the SERP as it provided prior to XXXXXXXXXX, but has not been designated in accordance with 7(c) above, such senior executive officer shall be entitled to the benefits accrued under the SERP as it read prior to XXXXXXXXXX to the date of exclusion, based on the senior executive officer's Contributory Service, Non-contributory Service, base salary and bonus up to the date of exclusion, paid upon the senior executive officer's Retirement, termination of employment, or death.

10. The SERP will be amended to provide that:

(a) The Corporation will have the discretion to grant a portion of a Participant's past service, to a maximum of XXXXXXXXXX years, with the Corporation, its subsidiaries or affiliates, as Service for purposes of the SERP; and

(b) Pensions in respect of any past service credits under the SERP will be guaranteed payable for a minimum of XXXXXXXXXX months.

11. The Corporation will, in determining a Participant's annual bonuses, take into consideration all of the Participant's compensation and benefits, including SERP benefits, automobile benefits, club membership benefits and other perquisites.

Purpose of the Proposed Transactions

12. The purpose of the proposed transaction is to ensure that all senior executive officers are eligible to receive pension benefits under the SERP that reflect some of their service with the Corporation, its subsidiaries and its affiliates.

Additional Information

13. To the best of your knowledge, the Corporation's knowledge and any Participants' knowledge, none of the issues involved in this ruling are:

(i) in an earlier return of the Corporation or a Participant, or any person related to the Corporation or a Participant;

(ii) being considered by a tax services office or tax centre in connection with a previously filed tax return of the Corporation or a Participant, or any person related to the Corporation or a Participant;

(iii) under objection by the Corporation or a Participant, or any person related to the Corporation or a Participant;

(iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; nor

(v) the subject of a ruling previously issued by the Directorate to the Corporation or a Participant.

Rulings

Provided that:

(i) the preceding statements constitute a complete and accurate disclosure of all of the relevant facts, definitions, the SERP, the proposed transactions and the purpose of the proposed transactions; and

(ii) the wording of the SERP is amended as described above, and thereafter continues to be substantially as described above,

we rule as follows:

A. The SERP, in its application to a Participant, will not constitute a salary deferral arrangement as that term is defined in subsection 248(1) of the Act as a result of, in and by itself, the crediting of past service under the SERP on behalf of the Participant as described in 10 above.

B. Provided that the SERP remains unfunded, the SERP, in its application to a Participant, will not constitute a "retirement compensation arrangement" as that term is defined in subsection 248(1) of the Act as a result of, in and by itself, the crediting of past service under the SERP on behalf of the Participant as described in 10 above.

C. Each payment made to a Participant or the Participant's beneficiary, as the case may be, under the SERP by the Corporation as a result of, in and by itself, the crediting of past service under the SERP on behalf of a Participant as described in 10 above, will be included in the income of the recipient in the year it is received as a superannuation or pension benefit pursuant to subparagraph 56(1)(a)(i) of the Act.

D. No amount will be included in the income of a Participant under subsection 5(1) or paragraph 6(1)(a) of the Act as a result of, in and by itself, the crediting of past service under the SERP on behalf of a Participant as described in 10 above.

E. Subsection 12(4) of the Act will not apply to a Participant to require any amount to be included in computing the Participant's income for a year as interest in respect of any entitlement the Participant may have pursuant to the proposed amendments to the SERP.

The above rulings, which are based on the Act in its present form and do not take into account any proposed amendments thereto, are given subject to the general limitations and qualifications set out in Information Circular 70-6R5 dated May 17, 2002, and are binding on the CRA provided that the proposed amendments to the SERP are implemented by XXXXXXXXXX.

Yours truly,

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