30 November 1995 Ruling 9610043 - XXXXXXXXXX MUTUAL FUND

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.

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

Principal Issues:

WILL XXXXXXXXXX MUTUAL FUND RESULT IN A DISPOSITION

Position: NO

Reasons:

RIGHTS OF UNITHOLDERS WILL NOT BE SIGNIFICANTLY CHANGED

									961004
XXXXXXXXXX

Attention: XXXXXXXXXX

XXXXXXXXXX, 1996

Dear Sirs/Mesdames:

Re: XXXXXXXXXX
Advance Income Tax Ruling ("Ruling")

This is in reply to your letters dated XXXXXXXXXX, 1996 wherein you requested an advance income tax ruling on behalf of

XXXXXXXXXX

XXXXXXXXXX

You confirm, on behalf of XXXXXXXXXX, that none of the issues or matters in respect of which rulings are requested is being considered by an office of Revenue Canada in connection with a tax return already filed nor is the subject of a notice of objection.

XXXXXXXXXX are providing information herein in confidence for purposes of the Act. Disclosure of this information is restricted pursuant to section 241 of the Act and as such is exempt from disclosure under the Access to Information Act (Canada).

Facts

The facts, as we understand them, are as follows:

1. XXXXXXXXXX

XXXXXXXXXX

XXXXXXXXXX

Rulings Given

Provided that the preceding statements constitute a complete and accurate disclosure of all relevant facts, the proposed transactions and the purpose thereof and the proposed transactions are carried out in the manner described above, we confirm the following:

38. (i)The Proposed Transactions described in paragraphs 27, 28, 29 and 31 will not, in and of themselves, result in the disposition by unitholders of all or part of their units in a Fund within the meaning of the definition of "disposition" in section 54 of the Act.

(ii) XXXXXXXXXX

(iii) XXXXXXXXXX

These rulings are given subject to the limitations and qualifications set forth in Information Circular 70-6R2 dated September 28, 1990 issued by Revenue Canada provided that the Proposed Transactions are completed on or before XXXXXXXXXX.

Yours truly,

for Director
Resources, Partnerships and Trusts Division
Income Tax Rulings and Interpretations Directorate
Policy and Legislation Branch