29 June 1990 Ruling 901301 F - Trust Administration

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.

This is in reply to your letter of June 14, 1990 wherein you requested our comments on several matters resulting to certain trusts which you must administer.

Since the subject matter of your queries appears to relate to both proposed and completed transactions we are unable to provide you with our opinions on the issued raised.

When a request relates to a proposed transaction it must be the subject matter of an advance income tax ruling submitted in accordance with the procedures set out in Information Circular IC-70-6R, a copy of which is attached.  A proper request entails the provision of all related documents for our review as well as an identification of all of the specific provisions of the Income Tax Act (the "Act") in respect of which the request is to be considered.  A ruling request must also contain a statement as to whether or not any of the issues involved are to the best of the taxpayer's 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.  Please note that the hourly rate for rulings is now $80, the required deposit is $400, and there is no longer a minimum charge.

When a request relates to a completed transaction it must be made through the District Taxation Office for the taxpayers involved. At the discretion of the District Office they may then consult with us and obtain our views on the matter.

Yours truly,for Director Financial Industries DivisionRulings Directorate