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 991913
Attention: XXXXXXXXXX
XXXXXXXXXX, 1999
Dear Sirs:
Re: XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
XXXXXXXXXX
Advance Income Tax Ruling 983067
We are writing in response to your letter of XXXXXXXXXX, wherein you asked for the following modifications to the proposed transactions set out in the above-noted Advance Ruling, dated XXXXXXXXXX, 1999:
1. The phrase "prior to XXXXXXXXXX" in paragraph 18 is be modified to read, "prior to the assignment of the XXXXXXXXXX". This change reflects the fact that the implementation of the XXXXXXXXXX Agreement has been delayed.
2. Subparagraph (a) of paragraph 19 is to be deleted as the XXXXXXXXXX is not requiring changes to the relevant pension plans as a condition precedent to the implementation of the XXXXXXXXXX Agreement.
We acknowledge the forgoing modifications to Advance Ruling 983067 and confirm that, subject to the conditions set out in Advance Ruling 983067, the rulings given therein will continue to be binding on Revenue Canada in accordance with the practice outlined in Information Circular 70-6R3, dated December 30, 1996, provided that the proposed transactions are completed in the manner described in Advance Ruling 983067, as amended herein, by XXXXXXXXXX.
Yours truly,
for Director
Reorganizations and International Division
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch