18 January 1990 Income Tax Severed Letter

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.

Revenue Canada Taxation MEMORANDUM

TO - Specialty Ruling Directorate
          Mr. M. Hiltz
          Director, Reorganization and
            Non-Resident Division

FROM - HEAD OFFICE
                  International Audits Division
                  J.A. Calderwood 952-7472

Attention Mr. K.H. Major
                Chief, Foreign Section

SUBJECT: XXXX

Article XIII(8) Canada - U.S. Tax Convention (1980)

Attached is a copy of the information which we recently received from the taxpayer's representative concerning the shareholdings in the U.S. companies and each company's status as a U.S. real property holding companies under the U.S. Internal Revenue Code.

We would appreciate if you would advise us when we might expect to receive a reply to our memorandum of June 29, 1989 in which we sought your opinion on whether Article XIII applies to the above case.

J.A. Calderwood Director International Audits Division Taxation Programs Branch

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