19 October 1989 Income Tax Severed Letter AC32270 - Periodic Use of Accommodation not Benefit

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.

3-2270
                  19(1)                       G. Thornley
                                              613-957-2101
October 19, 1989

Dear Sirs:

This is in reply to your letter of September 11, 1989, requesting further consideration of arguments that the periodic use of accommodation by a resident in the circumstances of your ruling request does not give rise to a benefit in the hands of such resident.

We have read your submission and consider your arguments, however, we are still of the view that there is taxable benefit to a resident.

We believe that we fully understand your views and position in this matter, however if you feel a further meeting would be useful we are receptive to same.

Would you please advise us by October 31, 1989 as to whether you wish us to proceed with the ruling request.

Yours truly,

Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch