17 August 1990 Income Tax Severed Letter ACC 9298 - Advance Income Tax Ruling

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.

24(1)
                                               901499
                                               S. Leung
                                               (613) 957-2116

Attention 19(1)

August 17, 1990

Dear Sirs:

Re: Advance Income Tax Ruling 3-2438 dated June 23, 1990 (the Ruling Letter) Paragraph 55(3)(a) of the Income Tax Act (The "Act")

We are writing in response to your letter of July 5, 1990 wherein
you inquired whether we would favourably consider a request for an
advance income ruling where                    24(1)

It is our understanding form our telephone conversation of July 31, 1990 19(1) Leung) that the proposed transactions described int he Ruling Letter have been completed.

As was discussed in our above noted telephone conversation, we would consider a request for a new advance income tax ruling in connection with the above mentioned matter provided that a full disclosure of the facts,. proposed transactions and purpose of the proposed transactions in respect of new ruling request is made, as set out in Information Circular 70-6R.

Yours truly,

for Director Reorganization and Non-Resident Division Rulings Directorate Legislation and Intergovernmental Affairs Branch