| September 12, 1989 | |
| Legislative Affairs Directorate | Specialty Rulings |
| Directorate | |
| Roy C. Shultis, Director | D. Watson |
| Publications Division | 957-2121 |
| File No. 7-4287 |
Subject: Publication of Advance Income Tax Ruling #3-2341
In response to your memorandum of August 29, 1989 we advise that the above referenced ruling is suitable for publication because it involves topics of current interest to the public, that is, the purification of a Canadian controlled private corporation and the crystallization of the capital gains deduction.
We have edited a copy of your draft publication which is enclosed for your consideration. Our suggestions which are not self evident are discussed below.
1. In paragraph 8, it is stated that Mr. Y is the brother of Mr.X. If ruling C is to have meaning, it is imperative that the shares be sold to someone who deals non-arm's length with Mr. X for the purposes of section 55 of the Act. We suggest that Mr. Y be described as the son of Mr. X.
2. The fact that the land for the house and the restaurant is 24(1) We suggest that this aspect be eliminated by deleting the appropriate references in paragraphs 4 and 6.
We hope these comments are of assistance.
M.A. Hiltzfor Director GeneralSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch