12 December 1989 Income Tax Severed Letter ACC8821 F - Survey

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.

24(1)

We have completed the attached survey to the best of our ability.  While our system fits within the survey, since we do transfer information to foreign revenue authorities, much of our work is on a request basis.

We have a few comments in regard to the survey according to the page. You might wish to review the answer in the light of the comment.

Question 1

We assumed that taxpayers should be considered as clients, although it is not an apt description.

Question 6

We have listed countries where we have sent information, but this does not happen on a regular basis with most countries. While we have a treaty with one Eastern European country (U.S.S.R.) we have not had any transmission of information.

The three Western European countries do not have a large flow.  The African countries are difficult to list because we have had little or no exchange, except Morocco.

Question 7

It is very difficult to answer this question because we do not have specific rules other than that it must be for the purpose of administering a tax covered by the convention. While we have marked some, others could be relevant depending upon the circumstances.  The best answer would be the general answer.

Question 8

We have written in another category.

Question 10

Normally we do not advise individuals when information is sent out.  In a case involving the resolution of a double taxation case the taxpayer would know that we were transmitting information, because he would have requested our intervention.

Question 11

All information is given on the basis that it will be used only for very limited purposes and the confidentiality is to be protected.  We have not gone into the question of the physical storage of the data.

Should you wish to discuss this, please let us know. We have made the answers in pencil should you wish to vary them.

C. Savage A/Director Provincial and InternationalRelations Division

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