1993 Administrative Letter 9336656 F - Paragraph 5000(1) of the Income Tax Regulations -- summary under Subsection 5000(1)

In response to an expressed concern that a trust or corporation could inadvertently have excess foreign property where it undertook to simultaneously acquire or dispose of more than one property but had to record the transactions at different times because of the way the transactions were actually processed, RC indicated that although the wording of the regulation was clear (the 20% limitation could not be exceeded even for a moment), it recognized that there may be reason to provide relief where simultaneously initiated transactions are recorded at different times due solely to the application of routine procedures.