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: changes in facts which did not affect rulings (ie incorporating act and amounts of certain shares)
Position:
Reasons:
XXXXXXXXXX
XXXXXXXXXX 2000-000681
XXXXXXXXXX
Attention: XXXXXXXXXX
XXXXXXXXXX, 2000
Dear Sirs:
Re: Advance income tax ruling #992399 dated
XXXXXXXXXX, 1999 issued to XXXXXXXXXX
XXXXXXXXXX (the "Ruling")
We are writing in response to your letter of XXXXXXXXXX wherein you advised us of certain changes to the Ruling. Capitalized terms not defined herein have the meanings ascribed to them in the Ruling.
1. The references in paragraphs 8 and 20 of the Ruling to the XXXXXXXXXX should be changed to the CBCA.
2. The amount of XXXXXXXXXX in paragraph 10 of the Ruling should be changed to XXXXXXXXXX.
3. The references in paragraph 33 of the Ruling to the amount of XXXXXXXXXX should be changed to XXXXXXXXXX.
You have advised us that there have not been any other changes to the relevant facts and proposed transactions described in the Ruling. Subject to the conditions stated therein, the Ruling will continue to be binding on the Canada Customs and Revenue Agency.
Yours truly,
for Director
Reorganizations and International Division
Income Tax Rulings Directorate
Policy and Legislation Branch