12 January 1990 Income Tax Severed Letter 59237A F - Payment of Legal Fee

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.

January 12, 1990

Dear Sirs:

Re: 19(1) Payment of Legal Fees

We are replying to your letter of December 11, 1989, which was further to our previous exchange of correspondence and telephone conversations, on the subject of legal costs paid by 24(1) , the employer, on behalf of  19(1)  an officer of the company.

As was indicated in one such telephone conversation the determination of the taxability of any benefit received by 19(1) is based on the facts of the particular case, and such determinations are normally made at the district office level.

Accordingly, we have forwarded the complete file to the Halifax District Office to the attention of Mr. H.K. Hingston, Chief of Audit, for his review, along with our comments. Mr. Hingston may be reached at (902) 426-2437.

We trust the matter will be resolved to your satisfaction.

Yours truly,

for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch

c.c.       H.K. Hingston Chief of AuditHalifax District Office