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.
XXXXXXXXXX 5-991191
Attention: XXXXXXXXXX
XXXXXXXXXX, 1999
Dear Sirs:
Re: Advance income tax ruling #3-990590
dated XXXXXXXXXX, 1999 issued to
XXXXXXXXXX (the "Ruling Letter")
We are writing in response to your facsimile transmission dated XXXXXXXXXX wherein you requested a change in the Ruling Letter. As a result, the following should be added to the end of Ruling C.:
"For greater certainty, the proposed transactions described herein, in and by themselves, will not be considered to result in a disposition or increase in interest described in subparagraphs 55(3)(a)(i) to (v) with respect to the dividends referred to in this ruling."
You have advised us that there have not been any other changes to the relevant facts and proposed transactions described in the Ruling Letter. Subject to the conditions stated therein, the Ruling Letter will continue to be binding on Revenue Canada.
Yours truly,
for Director
Reorganizations and International Division
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch