24 May 1991 Ministerial Correspondence 911344 F - Publication of Advance Income Tax Ruling 3-2398

By services, 18 January, 2022
Official title
Publication of Advance Income Tax Ruling 3-2398
Language
French
CRA tags
110.6(2.1), 245(2)
Document number
Citation name
911344
Severed letter type
Ministerial Correspondence
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
629677
Extra import data
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"field_release_date_new": "1991-05-24 08:00:00",
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Main text

Publication of Advance Income Tax Ruling 3-2398 (the "Ruling")

In your memorandum of May 14, 1991, you requested our view regarding the suitability of the Ruling for publication.  The main issue in the Ruling involves the application of subsection 245(2) of the Income Tax Act to a transaction whereby an individual crystallizes the capital gains deduction under subsection 110.6(2.1) of the Act.

While we may have originally recommended that the Ruling be published, the main issue in the Ruling has since been dealt with in paragraph 3 of Information Circular 88-2 Supplement 1. Therefore, in our view, publication of the Ruling is no longer necessary or advisable.

for DirectorReorganizations and Non-resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch