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
XXXXXXXXXX 992749
XXXXXXXXXX
Attention: XXXXXXXXXX
XXXXXXXXXX, 1999
Dear Sirs:
Re: Advance Tax Ruling 991540
We are writing in response to your letter dated XXXXXXXXXX, wherein you requested certain amendments to advance income tax ruling 991540 dated XXXXXXXXXX, 1999 (the "Ruling").
As a result, the following change is made to the Ruling.
The second sentence in paragraph 21 on page 10 is deleted and replaced by the following:
"The common shares of each Contracting Company will be beneficially or legally owned by
(a) the respective Professional;
(b) a person related to the respective Professional within the meaning of subsection 251(2) of the Act;
(c) a registered charity;
(d) other dependents of the respective Professional;
(e) a person not related to the respective Professional or any other Professional, solely in their capacity as trustee; or
(f) any combination of persons referred to immediately above in paragraphs (a) to (e)."
We confirm that the above change will not otherwise affect the rulings given in the Ruling and they will continue to be binding on the Department as indicated therein.
Yours truly,
XXXXXXXXXX
for Director
Resources, Partnerships and Trusts Division
Income tax Rulings and Interpretations Directorate
Policy and Legislation Branch