1999 Ruling 9905893 - SPECIFIED LEASING PROPERTY

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.

XXXXXXXXXX
XXXXXXXXXX 990589
XXXXXXXXXX

Attention: XXXXXXXXXX

XXXXXXXXXX, 1999

Dear Sirs:

Re: XXXXXXXXXX
XXXXXXXXXX ("Purchaser 1")
XXXXXXXXXX ("Purchaser 2")
XXXXXXXXXX ("Purchaser 3")
XXXXXXXXXX ("Purchaser 4")

This is in response to your letter of XXXXXXXXXX, regarding the advance income tax ruling (our file 983261) issued to your firm on XXXXXXXXXX, 1999 on behalf of the above-noted taxpayers

You have advised that all of the proposed transactions described in the advance income tax ruling have been completed except the purchase by Purchaser 2 of the leased property described in paragraph 3(v) of the advance income tax ruling. We understand that XXXXXXXXXX, as a condition to granting the transfer of the leased property, wants to be given indemnity for any federal or provincial sales taxes that may be payable as a result of the transfer of the leased property and assignment of the leases.

We confirm that the granting of the indemnity will not affect the rulings given in the advance income tax ruling provided that the purchase of the leased property referred to above is completed by XXXXXXXXXX.

Yours truly,

for Director
Financial Industries Division
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch

2

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