21 August 1990 Ruling 901413 F - Butterfly Transactions

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.

August 21, 1990

Dear Sirs:

Re: Advance Income Tax Ruling 24(1)

This is further to our telephone conversation of July 17 and August 2, 1990 (19(1) Diguer) concerning your request for an advance income tax ruling, dated June 20, 1990, submitted on behalf of the above-noted taxpayers.

We are writhing to confirm that the proposed transactions as described in your earlier mentioned request do not comply with the requirements of paragraph 55(3)(b) of the Income Tax Act (Canada) (the "Act") as sought by the parties to the proposed transactions. In light of the above, and as previously discussed, we are unable to proceed with our review of your request until we receive a revised series of proposed transactions which would comply with the provisions of paragraph 55(3)(b) of the Act.

In the event that we do not receive the necessary information by September 14, 1990, we will have no alternative but to consider the ruling request to have been withdrawn and close our file on this matter.

Yours truly,

for Director Reorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch