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at a cost of $8,179. The Court permitted
PERSONAL TAX
$6,000 as a medical expense as being a IN THIS ISSUE
62(1) reasonable average cost to replace the
rugs.
MEDICAL EXPENSES - PERSONAL TAX
RETIREMENT HOMES MEDICAL EXPENSES - EMPLOYMENT INCOME
A CCRA spokesperson noted that CCRA SUPPLEMENTS AND ORGANIC BUSINESS/PROPERTY INCOME
will now permit a medical expense for the FOOD
CAPITAL GAINS
“attendant care” portion of the retirement In a July 11, 2002 Tax Court of Canada
residence rent paid by persons eligible to CORPORATE TAX
case, the Court noted that prescriptions
claim the “disability amount” - (requires a must be “recorded by a pharmacist” to FEBRUARY 18, 2003 FEDERAL
doctor’s certificate on Form T2201). qualify as a medical expense. The Judge BUDGET
The operator of the “retirement residence” commented: “whatever that accomplishes, MARRIAGE BREAKDOWN
should provide a receipt showing the “at- I do not know, but the legislation is clear FARMING
tendant care” portion of the rent. that they must be recorded by a pharmac-
ESTATE PLANNING
ist”.
This should not affect people in “nursing INTERNATIONAL
homes” as they always have been entitled Editor’s Comment GST
to claim the nursing home fees as a medi- It appears that the Court is suggesting that DID YOU KNOW...
cal expense. simply “recording by a pharmacist” may
allow a medical expense for necessary
MEDICAL EXPENSES - prescribed drugs and medicaments.
RENOVATIONS son may walk fairly well with an artificial
MEDICAL EXPENSES - ACNE leg (therefore no disability tax credit),
In a March 11, 2003 while others might have a great deal of
Technical Interpreta- FACIAL TREATMENTS
difficulty. It depends on the person’s own
tion, CCRA note that In a December 11, 2002 Technical Inter- muscle strength and the type of prosthesis
reasonable expenses to pretation, CCRA notes that where a tax- or orthosis required.
renovate or alter a dwel- payer makes a payment to an employee of
ling of an individual who lacks normal a dermatologist for facial treatments to In this case, the type of orthosis required
physical development, or has a severe and correct acne problems, the payments because of the existing but undeveloped
prolonged mobility impairment, to enable would likely be medical expenses on the limb still led to an inordinate amount of
the person to gain access to, or be mobile basis that a dermatologist is a “medical effort to walk. Therefore, the DTC was
or functional within, the dwelling, would practitioner”. allowed.
be a medical expense.
DISABILITY TAX CREDIT (DTC) -
Also, in a January 7, 2003 Tax Court of ORTHOSIS EMPLOYMENT INCOME
Canada case, the taxpayer had a four year
old son who suffered from severe aller- In a May 9, 2002 Tax Court of Canada 62(2)
gies. Therefore, a doctor made a number case, the taxpayer suffered from poliomye-
TIPS PROJECT
of recommendations whereby the taxpayer litis and required the use of an orthosis to
get around. The Court noted that one per- In some Canadian
replaced the carpets with hardwood floors cities, including
Tax Tips & Traps
2003 SECOND QUARTER ISSUE NO. 62 PAGE 1
Calgary, CCRA are carrying out projects cards, day timers, trade publications, as ducing new legislation.
with respect to unreported tips in the hos- well as vehicle expenses, as confirmed in
pitality industry. We understand that the Form T2200 signed by the employer. MUTUAL FUNDS
CCRA may just go back one year. Mutual funds may earn interest income,
The Court permitted most of the travel
dividends, foreign interest and capital
NON-COMPETE AMOUNTS expenses and expenses such as advertising,
gains. These types of income retain their
meals, supplies and long distance tele-
On March 11, 2003 the Federal Court of character when they are distributed to the
phones.
Appeal unanimously found that the receipt investors. Investors holding units of a
of a non-competition amount is tax-free. fund on distribution day must include that
BUSINESS/PROPERTY INCOME amount in income. Trusts distribute in-
The Court noted that:
come to avoid having the income taxed in
1. “No doubt many will consider the 62(3) the Trust at top tax rates. Therefore, if an
result of this case to be unsatisfactory AUTOMOBILE ALLOWANCE investor purchases units of a fund just be-
in terms of fiscal policy. I am sympa- fore it pays a distribution, that person will
In a January 10, 2003 Technical Interpre-
thetic to the view that it seems unfair be required to report all of the income.
tation, CCRA notes that an employer may
that the shareholder of a corporation
pay a reasonable automobile allowance to TAX-FREE RECEIPTS
who bargains for a non-competition
an employee and deduct up to 41 cents per
payment in the context of a sale of the In a 2002 Tax
kilometre for the first 5,000 kilometres and
shares is not taxed on the payment, Court of Canada
35 cents for each additional kilometre (45
even though in economic terms it may case, IPSCO sued
cents/39 cents for the Yukon Territory,
represent the realization of a substan- a supplier for
Northwest Territories and Nunavut).
tial part of the commercial value of additional costs
the business of the corporation. Also, these per kilometre amounts will be of $7.6 million which they incurred be-
However, it is one thing to recognize considered reasonable, and therefore not cause of the acquisition of a faulty pipe
an unsatisfactory state of affairs, and taxable as employment income. However, treatment system. IPSCO received an out-
quite another to repair it.” CCRA also notes that where the payment of-court settlement of $4.8 million. For
exceeds the prescribed amounts, it may accounting purposes, IPSCO reduced the
2. The payments received under the non- still be considered reasonable, and not cost of the asset but, for tax purposes they
competition agreements were not pro- taxable, given the proper circumstances. showed the $4.8 million as a tax-free re-
ceeds of disposition of property and, ceipt. CCRA reassessed on the basis that
are not capital gains, they are tax- An amount will be deemed not to be rea-
the asset cost should also be reduced for
free. sonable unless it is based solely on the
capital cost allowance purposes.
number of employment kilometres driven.
Editor’s Comment
Good News!
This case may cause the Department of INTEREST EXPENSE
The $4.8 million was found to be a tax-
Finance to amend the Income Tax Act to The February 18, 2003 Federal Budget
free receipt with no reduction in the cost
deal with non-competition receipts. notes that the Department of Finance is not
of assets acquired.
Therefore, it may be wise to take advan- pleased with recent Supreme Court deci-
tage of this decision prior to any legisla- sions which permit interest expense de- Also, in a November 28, 2002 Federal
tive amendment. ductions when personal debt is reorga- Court of Appeal case, the taxpayer re-
nized into investment debt or, where the ceived $12 million from the City of Toron-
COMMISSION SALESPERSON interest expense is significantly higher to on a quasi expropriation of their build-
In a November 26, 2002 Tax Court of than the income generated. Therefore, the ing - $2.9 million for the land, $.1 million
Canada case, Mr. Gajos was a sales em- Department of Finance proposes to intro- for the building, and $9 million “in respect
ployee of Future Shop Ltd. paid on com- duce interest deductibility legislation of damages occasioned as a result of the
mission. He was required to sell in the shortly with a period of public consultation inability of the appellant to relocate its
main store as well as do comparison to follow. business”. CCRA argued that the $9 mil-
shopping at other stores and attend train- lion should be shown as a disposition of
ing sessions. He incurred expenses such Editor’s Comment eligible capital property with three-
as the acquisition of supplies, business It may be important to restructure debt quarters, or $6.5 million, shown as taxable
prior to the Department of Finance intro-
Tax Tips & Traps
2003 SECOND QUARTER ISSUE NO. 62 PAGE 2
income.
CORPORATE TAX FEBRUARY 18, 2003 FEDERAL
Good News! 62(5)
BUDGET
The Court found that the $9 million was a 62(6)
non-taxable capital receipt. SHAREHOLDER AGREEMENT -
DEEMED CONTROL/DEEMED On February 18, 2003, the Honourable
ASSOCIATION John Manley, Minister of Finance, pre-
CAPITAL GAINS The Income Tax Act extends the control sented his first Budget to the House of
and association concepts to situations Commons.
62(4)
where a shareholder has a right under a Some of the more important tax changes
PRINCIPAL RESIDENCE contract, in equity or otherwise, either include:
EXEMPTION immediately or in the future and either
It is noted on Page 42 of absolutely or contingently to acquire Child Disability Benefit
CCRA’s Capital Gains shares... He/she will be deemed to have A $1,600 Child Disability Benefit (CDB)
Guide (T4037) that the owned those shares unless the right is un- for children who meet the criteria for the
amount of land that is der a death, bankruptcy or permanent disability tax credit (DTC).
considered as a tax free disability.
principal residence on Medical Expense Tax Credit
In a January 7, 2003 Technical Interpre-
disposition is usually limited to one-half New eligible medical expenses including:
tation, CCRA reviewed a situation where
hectare (1.24 acres). However, if a tax-
the shares of OPCO were owned by Cor- Real-time captioning for individuals
payer can show that more land was needed
porations A, B and C which were subject with a speech or hearing impairment;
to use and enjoy the property, that amount
to the following “cash-call provision”.
is eligible as a principal residence. For Note-taking services used by individ-
example, if the minimum lot size imposed 1. Under certain circumstances OPCO uals with mental or physical impair-
by a municipality at the time you bought can issue a demand for cash to each ments and the cost of voice recogni-
the property is larger than one-half hec- shareholder in proportion to its share- tion software used by individuals with
tare. holdings; a physical impairment as certified by
2. If a shareholder fails to advance the a medical practitioner; and
CAPITAL DIVIDEND ACCOUNT
funds, another shareholder may ad- The incremental cost associated with
(CDA)
vance the funds; the purchase of gluten-free food for
If a corporation had taxable capital gains
in the three preceding years, the corpora- 3. If the defaulting shareholder fails to individuals with celiac disease.
tion may trigger a capital loss on its loser repay the advancing shareholder
within 90 days, the advancing share- Registered Pension Plan (RPP)
investments in the current year to be car- and Registered Retirement Sav-
ried back against those taxable capital holder may cause OPCO to propor-
tionately reduce the defaulting share- ings Plan (RRSP) Limits
gains. However, it is important to remem-
holder’s shareholdings in OPCO. The money pur-
ber to pay out the CDA on the capital gain
chase RPP limit
before the capital loss is triggered. For Bad News! will be increased
example, if a corporation had a capital CCRA to $15,500 for
gain in 2000 of $100, taxable capital gain concluded 2003, $16,500 for
of $75 and CDA of $25, it is important to that each 2004 and $18,000 for 2005.
elect to pay the tax free $25 CDA before a corpora-
capital loss is triggered in 2003 which tion would The RRSP limit will be increased to
effectively negates the CDA if the CDA is be $14,500 for 2003, $15,500 for 2004,
not paid out before triggering the capital deemed to own all the shares of the other $16,500 for 2005 and $18,000 for 2006.
loss. corporation for control and association Small Business Deduction
purposes.
The small business deduction reduces the
basic federal corporate income tax rate to
12 per cent for the first $200,000 of active
Tax Tips & Traps
2003 SECOND QUARTER ISSUE NO. 62 PAGE 3
business income of a Canadian-controlled marriage or common-law partnership. riage to common-law partners would “nul-
private corporation (CCPC). lify the individual’s freedom to choose
In a favourable 2002 Advance Income
alternative family forms, and to have that
The annual amount of active business in- Tax Ruling, the taxpayer and the spouse
choice respected by the state”.
come eligible for the reduced 12-per-cent had previously entered into a separation
tax rate will be increased to $225,000 agreement which provided for periodic REDO THE DEAL
(year 2003); to $250,000 (2004); to monthly support amounts.
It was noted in the October 28, 2002 issue
$275,000 (2205) and after 2005, to
The agreement is to be amended to delete of the National Post that Eric Miglin is
$300,000.
the future support payments and replace appealing an Ontario Court of Appeal
Federal Capital Tax them with a transfer from the taxpayer’s Decision to the Supreme Court of Canada.
Eliminate the .225 per cent federal capital RRSP to the former spouse’s RRSP on a The Ontario Court had ruled that Mr.
rollover basis. Miglin’s spouse could reopen their prop-
tax over five years, starting January 1,
erty settlement and alimony agreement if
2004. CANADA PENSION PLAN (CPP) - there are material changes and circums-
Resource Taxation CREDIT SPLITTING tances that would have likely led to a dif-
Change the taxation of resource income When a relationship ends, the Canada ferent agreement if they had been known
by phasing in, over a period of five years: Pension Plan pension credits which the at the outset.
a reduction of the corporate income tax couple built up during the time they lived In this case, Ms. M got the Toronto home
rate from 28 per cent to 21 per cent; a together can be divided equally between worth $500,000 as well as $60,000 a year
deduction for provincial and Crown royal- them. to support their four children. Mr. M re-
ties and mining taxes paid and the elimi- tained the Killarney lodge which receives
SUPPORT PAYMENTS
nation of the existing 25-per-cent re- millions of dollars annually. The Ontario
source allowance; and a new tax credit for It is noted in CCRA’s Guide Pl02, that if a Court adjusted the agreement to provide
qualifying mineral exploration expendi- person wishes to deduct alimony he/she Ms. M with an additional $4,400 a month
tures. must register their Order or Agreement by for personal support.
completing Form T1158. Also, a payor of
alimony may request CCRA to reduce the This case could affect thousands of di-
MARRIAGE BREAKDOWN amount of income tax that an employer is vorced couples who would like to redo
deducting from salary by completing Form their Divorce Agreement.
62(7)
1213 (Request to Reduce Tax Deductions
SPOUSAL SUPPORT MADE at Source). FARMING
AFTER DEATH
COMMON-LAW COUPLES 62(8)
In a February 26, 2003 Technical Inter-
pretation, CCRA notes that where Mr. A The December 20, 2002 issue of the Globe
is paying tax deductible support payments and Mail notes that common-law partners
(unlike married couples) do not have a SALE OF TIMBER
to his former spouse (Ms. A), if, upon Mr.
A’s death, the Estate is required to contin- guaranteed right to a 50-50 split of assets In a December 5,
ue to make the periodic payments, the when the relationship collapses based on a 2002 Tax Court of
amounts will not be deductible to the Es- recent Supreme Court of Canada case. Canada case, the tax-
tate, or be taxable to Ms. A. payers entered into a
This case involved Susan Walsh and
five-year plan to have trees removed from
Wayne Bona, a couple who cohabited for
RRSP ROLLOVER their farm property. The Court concluded
ten years and had two children. After the
The Income that the gain was capital (not business
breakup, Ms. Walsh wanted a share of the
Tax Act pro- income) even though the property was not
assets in Mr. Bona’s name. She sought to
vides for an being used for farming.
have Nova Scotia’s Matrimonial Property
RRSP rollover Act declared unconstitutional because it Arguments in favour of “capital” included
from one excluded common-law partners from its that the property was originally acquired
spouse to the other spouse under a division definition of spouse. The Court noted that with the intention of farming, the property
of property arising on the breakdown of a extending the legal consequences of mar- had been owned for over forty years and
Tax Tips & Traps
2003 SECOND QUARTER ISSUE NO. 62 PAGE 4
there was no timber sold until recently. for a reduction in the withholding tax to
ESTATE PLANNING
the maximum possible U.S. tax.
CCRA’s argument that the amounts should
be income on the basis that it was a sale 62(9) Also, some states have a withholding tax
based on production or use, was not cor- LOAN TO TERMINALLY ILL on the selling price of real property, in-
rect because it was really a single final POLICYHOLDER cluding Arizona and Hawaii.
transaction transferring all the timber. In a February 25, 2003 Technical Inter- The Canadian person then files a U.S. tax
Also, on January 3, 2003, CCRA intro- pretation, CCRA notes that the Financial return (Form 1040NR - Individual or
duced new IT-373R2 which discusses the Services Commission of Ontario has rec- Form 1120F - Corporation) and shows the
taxation of woodlots including woodlots ommended that life insurance companies withholding tax, if applicable, as a tax
operated as farms. The criteria needed for should provide funds to terminally ill po- installment. A foreign tax credit may be
capital treatment and capital gain exemp- licyholders who have a life expectancy of claimed on the Canadian tax return to the
tion are discussed. less than twenty-four months. extent that the income is taxed on the Ca-
While not legally obligated to provide nadian tax return.
SEASONAL AGRICULTURAL
WORKERS funding to these policyholders, many life EMIGRATION
insurers are considering providing loans
In February, 2003 CCRA introduced to the policyholders out of the insurer’s Individuals
Guide RC4004 - Seasonal Agricultural general funds. who cease
Workers Program. This Guide discusses to be resi-
how seasonal agricultural workers are SPOUSAL TRUSTS dent in
taxed, employer withholdings, waivers CCRA note in a Feb- Canada are
from withholding tax, transferring a work- ruary 4, 2003 Tech- deemed to have disposed of property at
er to another employer, and the filing of fair market value with the following ex-
nical Interpretation
tax returns, and double taxation issues. that where the income ceptions (Subsection 128.1(4)):
ROLLOVER TO CHILD of a spousal trust is (i) real property located in Canada;
payable to the
In a December 23, 2002 Technical Inter- (ii) property used in a business carried on
spouse, if the trustee would like the in-
pretation, CCRA notes that where farm through a Canadian permanent estab-
come taxed in the trust an election must be lishment;
property is rolled over to an adult child made. Otherwise, the amount must be
and the property is then sold within a deductible to the trust and included in in- (iii) certain “rights and interests”, such as
three year period by the child who uses come by the spouse. pension and deferred income plans,
the qualified farm property capital gain RPPs, RCAs, RRSPs, RRIFs, CPP,
deduction, CCRA can deny the tax de- OAS, etc.;
ferred rollover. INTERNATIONAL
(iv) employee stock options; and
NISA FUNDS - NOT SEIZABLE BY 62(10) (v) where the individual was resident in
CREDITORS U.S. REAL ESTATE SALES Canada for 60 months or less in the
It was noted in the December 12, 2002 last 120 months before leaving Can-
The United States imposes taxes on profits ada, any property owned by the indi-
issue of the Manitoba Co-operator that on the sale of U.S. real estate by a Cana-
the Manitoba Court of Appeal ruled that a vidual when the individual last moved
dian under the Foreign Investment in Real to Canada or inherited during the pe-
creditor may not seize the farmer’s NISA Property Tax Act. To enforce collection, a
account. This overturns a lower court riod of residency.
10% withholding tax is paid to the IRS by
ruling. (Mini G. Enterprises Ltd. vs. Gary the purchaser at the time of purchase. A The emigrating individual may defer pay-
and Ron Kendrick) Canadian person may be exempt from the ment of the tax on the capital gain by post-
10% withholding tax if the selling price is ing security with CCRA.
less than $300,000 and the buyer intends However, security is not generally re-
to use the property as a “residence”. The quired on the first $50,000 of taxable cap-
buyer must sign an affidavit to this effect. ital gains resulting from the deemed dis-
Alternatively, if this exemption is not position.
available, the vendor can apply to the IRS
Tax Tips & Traps
2003 SECOND QUARTER ISSUE NO. 62 PAGE 5
TRANSFER PRICING GST registration number. VOLUNTARY DISCLOSURE
It was noted in the December 30, 2002 On June 12, 2002, CCRA issued its re-
INTERNET SUPPLIES
issue of the Financial Post that about 85% vised Voluntary Disclosure Program
of Canada’s top sixty firms, and more than In December, 2002 CCRA released a (VDP) including the introduction of a pol-
half of the largest three hundred firms number of Rulings that discuss GST on icy to make a “no-name” disclosure on
listed on the Toronto Stock Exchange, use internet supplies to non-residents. Form VDP-1. The no-name disclosure
some form of transfer pricing, possibly For example, Ruling No. 33017 (August does not identify the name of the taxpayer
with the intent of transferring profits out- 16, 2002) notes that job search videos but should be complete and include all
side of Canada. which may be viewed by Canadians and relevant information to permit the CCRA
non-residents are considered to be “made officer to review the situation.
For example, a T-shirt costing $1 to make
may be manufactured in a tax haven coun- in Canada” and, therefore subject to GST. The taxpayer would then proceed with a
try and sold to a Canadian subsidiary for, However, this may not be the case had full disclosure by a negotiated deadline, or
say, $10 and then subsequently sold so that access been limited to non-resident cus- alternatively choose not to follow the Vo-
the $9 profit is earned outside Canada. tomers. luntary Disclosure process.
Therefore, CCRA has added 40 new audi- In another Ruling No. 32713, CCRA This Program is administered by CCRA’s
tors to the International Tax Department, Ruled that GST must be charged by an Appeals Division.
bringing a total of 278, whose job it is to internet radio station on fees received for
ensure that cross-border transfer pricing advertising various musician services as
is correct and that profits are not being this is considered to be supplied in Cana- DID YOU KNOW...
transferred outside of Canada. This is the da. 62(12)
“number 1” issue of CCRA’s International In another Ruling 32742, CCRA Ruled
Taxation Department. Therefore, most WEB TIPS
that digitized artwork available to resi-
accountants are advising clients to review dents and non-residents of Canada would 1. Financial Advice, Rates and Com-
their transfer pricing policies in light of be considered to be supplied in Canada. parisons
this recent CCRA attention. If you want information on finances,
KEEP THE INVOICES this site contains several useful tools,
GST One of the major reasons for GST reas- including mortgage amortization cal-
sessments is improper input tax credit do- culators, mortgage rate comparisons
62(11) cumentation. CCRA GST auditors require (updated daily), rent vs. own calcula-
SORRY - NO ITC proper invoices to support input tax cre- tors, retirement calculators, and
dits. For example, if the input tax credit is many more.
In an August 26, 2002 supported merely by a credit card slip, and
Tax Court of Canada (http://finance.canada.com/bin/putfo
not the invoice, it may not be allowed. rm?Type=Calculator or go to
case, Alexander Nix The source document should show the
Group Inc. purchased http://finance.canada.com and click
supplier’s GST registration number. This on the “calculators” button)
supplies from 864116 is not available on credit card receipts,
Ontario Ltd. (864). After being provided bank statements, and cancelled cheques This website is hosted by CanWest
with a GST registration number from which, some clients, use as substantiation Global Communications Corp. (Na-
864, the appellant paid $3,766 GST on for their input tax credits. tional Post, Global TV etc.)
$53,874 of services and then claimed the 2. Canadian Retirement Income Calcu-
$3,766 input tax credits (ITCs). The regis- REMITTING GST ON TAXABLE lator - https://srv260.hrdc-
tration number that 864 provided was the BENEFITS drhc.gc.ca/ or go to www.hrdc.gc.ca
company’s original GST number but was GST must be remitted on an employee and search for “Canadian Retirement
invalid as it had been deregistered years taxable benefit unless the benefit is zero- Income Calculator”.
earlier. rated or tax exempt - such as the benefit on Hosted by H.R.D.C., this calculator
The Court denied the ITC. The primary low-interest loans. Taxable benefits that provides a forecast of annual pre-tax
reason was because it was deemed the are not exempt include automobile stand- retirement income. With the use of a
appellant’s responsibility to obtain a valid by charges and operating expense benefits. seven module procedure, this tool al-
Tax Tips & Traps
2003 SECOND QUARTER ISSUE NO. 62 PAGE 6
lows users to manipulate most condi- This may significantly reduce income form. Generally, these letters implore the
tions that affect C.P.P. (i.e. taking it taxes if CPP income is shifted to a lower receiver to take part in a currency transfer
early or reducing the number of years income spouse. plan where the receiver is promised re-
paid into the plan), O.A.S., employer wards amounting to millions of dollars.
pensions, RRSP, and other income CHILD REARING DROP-OUT The intent of the sender is to abstract
amounts. Once the appropriate in- PROVISION - CPP money from the receiver in advance in the
formation is entered, a summary may It is noted in the Human Resources web- form of items such as unforeseen taxes,
be printed. One may then change site (www.hrdc.gc.ca) that where a person banking fees, and administration fees.
pieces of previously entered data and left the labour force and had a child under
If you receive a letter or proposal that has
print out the new summary sheet for the age of seven, these years may be ex-
these characteristics or is somewhat ques-
comparison. cluded in the calculation of the CPP bene-
tionable, contact “Phonebusters” (operated
fits. This has resulted in refunds to many
SPOUSAL C.P.P. SPLITTING by the Ontario Provincial Police) for
persons who have been receiving their
It is possible for more information at 1-888-495-8501,
CPP benefits but are only now advising
spouses and email: wafl@phonebusters.com, web:
HRDC of their children. To apply, the
common-law http://www/rcmp-grc.ca/scams/nigerian.
child’s birth or baptismal certificate will
partners to adjust be needed. For further information contact The website also includes valuable infor-
their CPP re- 1-800-277-9914. mation about other telemarketing scams,
ceipts so that each how to spot a scam, how to report a fraud
person receives WEST AFRICAN/NIGERIAN FRAUD and information on charges, arrests, counts
half of the LETTERS and sentencing.
pension earned for the years when the two Over the past few years, fraudulent letters
partners were together. claiming to originate in Nigeria and other
To make this “assignment” each partner West African nations have been received
must be at least sixty years old. by individuals. Recently, there has been a
resurgence in these letters in an email
The preceding information is for educational purposes only. As it is impossible to include all situations, circumstances
and exceptions in a commentary such as this, a further review should be done. Every effort has been made to ensure the
accuracy of the information contained in this commentary. However, because of the nature of the subject, no person or
firm involved in the distribution or preparation of this commentary accepts any liability for its contents or use.
Tax Tips & Traps
2003 SECOND QUARTER ISSUE NO. 62 PAGE 7
