18 July 1989 Ruling 32541 F - Advance Income Tax Ruling

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.

July 18, 1989

Dear Sirs:

Re:  Request for Advance Income Tax Ruling 24(1)

This is in reply to your letter couriered to us on June 30, 1989 wherein you requested the above-noted ruling.

Information Circular No. 70-6R paragraph 15 and 16 provide details of the procedures to be followed in requesting an advance ruling.  Paragraph 16 in particular requires (among others) that the request:

a.     include as clear statement of the questions on which the ruling is required;

b.     provide a frank inclosure of the purpose of the proposed transactions; and

c.     identify the specific provision of the Income Tax Act (the Act) with respect to which a ruling is sought, your interpretation of those provisions as they relate to the request and the reasons and authorities in support thereof. 

When a ruling is given generally provide that each of the provision of the Act as specified in c. above will or will not apply as the case may be.

A ruling must also contain a statement as to whether any of the issues involved are to the best of the taxpayers knowledge being considered by a District Office and/ or Taxation Centre in connection with a tax return already filed, or if any of the issues are under objection.

We would also like to note that in general, favourable and unconditional rulings could not be provided in respect of a plan which contain provisions which allow for the amendment, modification or interpretation of the plan at will.

We would be pleased to rule on the plan if it is resubmitted as described above. Your deposit will be returned under separate cover. Please note that the current deposit required is $325 and the hourly fee for rulings has been increased to $65.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate