3-910847
Dear Sirs:
Re: 24(1) Advance Income Tax Ruling Request
This is in reply to your letter of March 11, 1991 wherein you requested the above noted ruling request.
Since the subject matter of your request pertains directly with or is related to draft legislation on the Income Taxation of trusts as released on February 11, 1991 by the Honourable Michael Wilson, in his capacity as Minister of Finance, we are unable to provide you with any advance rulings at this time in accordance with paragraph 22 and the last sentence of paragraph 14 of Revenue Canada's Information Circular no.70-6R2, a copy of which is enclosed for your reference.
We would also like to note that, to be considered, a ruling request should be complete upon submission and include all relevant details and documents necessary for its review. Should you re-submit your request at a later date it should include copies of all relevant existing or proposed documents including any proposed draft trust variations as well as a complete disclosure of the settlements that have previously been made to the trusts and details of the interrelations of the parties involved including details of the corporate share ownership.
We would also like to draw to your attention the provisions of subparagraph (f) of paragraph 15 in the above-noted Information Circular.
We regret that we could not be of assistance to you at this time but trust that you understand our position with respect to your submission.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate