1999 Ruling 990115A - 21-YEAR RULE

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: Supplemental to Ruling 982495. The shares to be redeemed will be purchase for cancellation.

Position: Ruling will continue to be binding. The changes are not significant enough

to effect the rulings given.

Reasons:

XXXXXXXXXX
XXXXXXXXXX 1-990115
XXXXXXXXXX

Attention: XXXXXXXXXX

XXXXXXXXXX, 1999

Dear Sirs:

Re: XXXXXXXXXX
Advance Income Tax Ruling # 982495 (the “Ruling Letter”)

This is in reply to your facsimile of XXXXXXXXXX in which you advised that on XXXXXXXXXX purchased for cancellation a portion of the shares owned by the Trust and did not redeem such shares as described in paragraph 13 of the Ruling Letter. You also advised that this was done simply for corporate law purposes as a redemption by a corporation of some of a class of shares entitles all holders of these shares to such redemption. Finally you advised that, as it was not the intention of either corporation to redeem all of their shares issued and outstanding to all shareholders, a purchase for cancellation was conducted which in all respects is the same as a redemption.

In our opinion, the cancellation, rather than the redemption of the shares as described in paragraph 13 of the Ruling Letter, would not alter the conclusions in our Ruling Letter.

Yours truly,

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

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