30 November 1996 Ruling 9705483 - DISSOLUTION OF PARTNERSHIP IN A TIERED ARRANGEMENT

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.

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

Principal Issues:

1. Will minor amendment to the proposed transactions alter the ruling given?

Position:

1. No.

Reasons:

1. Change merely reflects a reduced loan balance that is being repaid. Nothing appears to turn on this fact.

XXXXXXXXXX							970548
XXXXXXXXXX

Attention: XXXXXXXXXX

XXXXXXXXXX, 1997

Dear Sirs:

Re: XXXXXXXXXX
Income Tax Ruling, Dated XXXXXXXXXX, 1997

This is in reply to your letter dated XXXXXXXXXX, wherein you requested that we replace paragraph 14 of the advance income tax ruling we issued to XXXXXXXXXX, dated XXXXXXXXXX, 1997 (our file number 963381, hereinafter referred to as the "Ruling") with the following:

"14. The partners of the XXXXXXXXXX Partnership will make capital contributions to the XXXXXXXXXX Partnership on a pro rata basis in the aggregate amount equal to the balance outstanding on the XXXXXXXXXXLoan. The capital contributions will be used by the XXXXXXXXXX Partnership to repay the XXXXXXXXXX Loan."

This change is required because a portion of the XXXXXXXXXX Loan has been repaid and it is expected that there may be further repayments prior to the implementation of the proposed transactions.

We confirm that the above change has been made and the balance of the Ruling remains unchanged.

Yours truly,

for Director
Resources, Partnerships and Trusts Division
Income Tax Rulings and Interpretations Directorate
Policy and Legislation Branch