28 November 1989 Ministerial Letter 58728 F - Tax on Corporate Distributions

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 28, 1989

Dear Sirs:

Re: 24(1)

We are writing in response to your letter of September 26, 1989 which outlined a matter relating to our letter to you (the "Opinion Letter") of November 25, 1987.

The Opinion Letter concerned the application of the provisions of section 183.1 of the Income Tax Act (the "Act"), as they read at that time with regard to 24(1)

You have indicated that in your view 24(1)

The provisions of section 183.1 of the Act were amended applicable with respect to transactions entered into on or after September 13, 1988, other than transactions that were part of a series of transactions, determined without reference to subsection 248(10) of the Act, commencing before September 13, 1988 and completed before 1989.

24(1)

In our opinion 24(1)

The above comments constitute an expression of opinion only and are not binding on the Department as detailed in Information Circular 70-6R dated December 18, 1978.

Yours truly,

for Director Reorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch