24 May 1989 Income Tax Severed Letter 3-2685 - []

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.

XXXX John Shaw (613)957-8983

May 24, 1989

Dear XXXX

Re:XXXX Advance Income Tax Ruling Requests

As discussed during our recent telephone conversation and during our meeting on May 17, 1989, most of the key issues in the above-captioned matter cannot be resolved until we and our advisors with the Department of Justice have had the opportunity to examine the related documentation. There are, as you know, a relatively large number of issues with respect to which we consider ourselves obliged to obtain an opinion from Justice. While a few of these matters can be examined by Justice without the related documentation, most cannot. We will be asking our advisors in Justice to commit for a significant amount of time their rather limited manpower in providing us with advice on these issues, and to the extent the documentation is essential to the resolution of the issues, cannot make this request of them before documentation which may reasonably be expected to reflect the agreement among the parties is available.

We understand that certain of your operational people are concerned with the prospect that we will have the documents in our possession and beyond their control. Our comments are, firstly, that without the documents we cannot provide the rulings requested. Secondly, we assure you that the documentation will be available only to those involved in Revenue's examination of the ruling request and those of our advisors with the Department of Justice who will provide us with legal opinions. Documentation obtained in the course of examining a ruling request is treated with the same care as returns filed with our Department or information which our Department obtains in the course of an audit - all these items are confidential and information which they contain will not be disclosed to third parties.

We cannot, of course, provide a list of documents which we would like to have, as we do not know what documentation is available. All available documentation pertaining to matters with respect to which rulings have been requested should be provided. In the event that there are documents which are not yet available, we would appreciate being advised as to when we may expect to receive them.

Yours truly,

for Director Bilingual Services and Resource Industries Division Rulings Directorate