6 August 1993 External T.I. 9320095 F - Change Fiscal Period

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.

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Dear Sir:

RE:  Change of fiscal period

This is in reply to your letter of July 6, 1993 and is further to our reply of June 15, 1993 to your letter of April 29, 1993.

You wish to find out if, in the situation outlined in your letter of April 29, 1993, there will be a termination of the taxpayer's first legal practice in one city with a resultant year end at the termination date and whether the start up of the same practice in another city will result in a new year end.

Since the taxpayer in question is a self-employed practitioner who already had an established fiscal year-end, the moving of his practice to another city does not in itself create, for fiscal purposes, a new year-end unless the taxpayer disposes of his practice in the prior city. Where the taxpayer does not dispose of his practice but continues his practice as a sole proprietor, his year-end remains the same. Accordingly, the Department's approval would be required to make a change to the taxpayer's established fiscal period.

We wish to point out that the review of an actual fact situation relating to a past transaction falls within the responsibility of the relevant District Taxation Office. The foregoing represents our views with respect to the subject matter of your letter, however, the facts of a particular situation may result in a different conclusion. Furthermore, the above comments are an expression of opinion only and are not binding on the Department as explained in paragraph 21 of Information Circular 70-6R2. We trust however that they are of assistance to you.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate