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 3-983057
XXXXXXXXXX
Attention: XXXXXXXXXX
XXXXXXXXXX, 1998
Dear Sirs:
Re: XXXXXXXXXX
Advance Income Tax Ruling
on our file number 3-983057
This is in reply to your letter of XXXXXXXXXX, in which you requested a change to the facts in our letter of XXXXXXXXXX, 1998 (the "Ruling"). You advised that XXXXXXXXXX had disposed of its limited partnership interest, described in paragraph 6 of the Ruling, on XXXXXXXXXX to XXXXXXXXXX for consideration of $XXXXXXXXXX. This disposition was a transaction that was totally independent of the Butterfly Transfer and was not carried out in contemplation of the Butterfly Transfer. (Terms defined in the Ruling to have a certain meaning have the same meaning when used in this letter.)
As a result of your letter, the words "investment in a limited partnership " on line 2 of Paragraph 6 of the Ruling will be deleted.
We confirm that the change described above will not affect the rulings given in the Ruling and will continue to be binding as indicated therein.
Yours truly,
for Director
Reorganizations and International Division
Income Tax Rulings and Interpretations
Directorate
Policy and Legislation Branch
??
2
.../cont'd
.../cont'd