16 February 1990 Ruling 32943 F - Deferred Salary Leave Plan

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.

February 15, 1990

Dear Sir:

Re:  Deferred Salary Leave Plan ("Plan")

This is in reply to your letter dated January 19, 1990 in which you requested an advance income tax ruling with respect to the proposed Plan, and is further to our letter dated November 9, 1989. You provided us with copies of the revised Plan and of the Memorandum of Agreement.

As discussed by 19(1) and Mr. A.B. Adler vis telephone on January 31, 1990 your ruling request is cancelled, and we will provide you with our comments concerning your revised Plan. Further, your deposit of $325 will be refunded under separate cover.

Our comments follow.

1.     24(1)

2.     24(1)

3.     24(1)

4.     24(1)

5.     All references to an advance income tax ruling in the Plan should be deleted.

Should the Plan be revised as indicated above, it is our view that it will meet the requirements of paragraph 6801(a) of the Regulations.

As discussed, the views expressed in this letter are not binding on this Department. We trust, however, that they will be of assistance to you.

Yours truly,

for Director Financial Industries Division Rulings Directorate