| 19(1) | File No. 5-8887 |
| R.C. O'Byrne | |
| (613) 957-2126 |
February 23, 1990
Dear Sirs:
Re: Subsection 126(2) of the Income Tax Act (the "Act") and Interpretation Bulletin IT-183 ("IT-183")
This is in reply to your letter of October 13, 1989 regarding the above-referenced subjects.
In our opinion a Canadian resident taxpayer who is a member of a partnership which carries on a business in a foreign country would be considered to be carrying on that business in that foreign country and would be entitled to claim his share of the partnership business-income tax paid as a foreign tax credit pursuant to subsection 126(2) of the Act.
We trust this will be of assistance to you.
Yours truly,
for DirectorReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch