9 November 1990 Ministerial Letter 53058 F - Confirmation of Tax Shelter Benefits of an Investment

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.

November 9, 1990

19(1)

24(1)

We are writing in reply to your letter of October 24, 1990 wherein you asked for confirmation of the tax shelter benefits of an investment in the above-noted corporation. You have also requested confirmation of the Department's approval of this arrangement.

As discussed with you, we are unable to respond to your request since it is not our practice to comment on the promotional representations or the merits of specific tax shelter arrangements. Due to the confidentiality provisions of the Income Tax Act, we cannot disclose the content of any correspondence with any taxpayer with a third party unless we have specific authorization from the taxpayer allowing us to do so. We can, however, assure you that the Department has in no way provided approval of any aspect of this or any other tax shelter by virtue of assigning a tax shelter registration number.

In your letter you referred to our file #5-9350. The prefix "5" in our file reference system means that the Department has provided information only or non-binding opinions on income tax matters raised. File numbers on rulings that bind the Department to particular tax consequences of proposed transactions would be prefixed by the number "3" or the number "1". Regardless of the type of file, our responses may or may not agree with or support the views of the enquirer.

We would like to thank you for bringing your concerns regarding the above-noted company to the attention of the Department.

Yours truly,

for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch