1999 Ruling 9931893 - LOSS UTLILIZATION

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: Additional Ruling

Position: OK

Reasons: 111(1)(A)

XXXXXXXXXX 993189

Attention: XXXXXXXXXX

XXXXXXXXXX 1999

Dear Sirs:

Re: Advance Income Tax Ruling
XXXXXXXXXX

This is in response to our telephone discussion (XXXXXXXXXX) on XXXXXXXXXX, concerning the above-noted advance income tax ruling (file # 991140) wherein you requested an additional ruling on the application of section 111 of the Act and an amendment to the ruling in respect of subsection 245(2) of the Act on behalf of the above-noted taxpayers.

Additional and Amended Rulings

1. Ruling B is replaced as follows:

"BCO will be entitled to carry back to and deduct from its taxable income for the taxation year ending XXXXXXXXXX, any non-capital loss incurred in its taxation year ending XXXXXXXXXX or to carry such non-capital loss forward and deduct it from its taxable income for a subsequent taxation year within the limits provided in paragraph 111(1)(a) of the Act."

2. Original Ruling B is renumbered as Ruling C and will also apply to the additional ruling provided above.

These rulings are given subject to the general limitations and qualifications set out in Information Circular IC 70-6R3 dated December 30, 1996, and are binding on the Agency provided that the proposed transactions described in the original ruling are completed by XXXXXXXXXX.

Yours truly,

for Director
Financial Industries Division
Income Tax Rulings
and Interpretations Directorate