| 19(1) | 5-8997 |
| Bill Guglich | |
| (613) 957-2102 |
December 4, 1989
Dear Sirs:
Re: 24(1) Advance Income Tax Ruling 3-1972
This is in reply to your letter of October 26, 1989, wherein you requested an extension of time of at least six months for the completion of the proposed transactions outlined in Advance Income Tax Ruling 3-1972 dated September 16, 1988.
You advise that the parties are proceeding toward completing the transactions originally described and that despite continuing delays there have been no significant changes to the facts or intentions of the parties as described in the above referenced advance ruling.
Ruling Given
Provided your statement that there are no significant changes to the facts when taken together with the statement of facts and proposed transactions set out in our ruling of September 16, 1988 is accurate and constitutes complete disclosure of all relevant facts and proposed transactions we rule that your request for a six months extension of time for the completion of the Exchanges does not affect our rulings given in our letter of September 16, 1988.
This ruling and the rulings given in our letter of September 16, 1988 are given subject to the general limitations and qualifications set forth in Information Circular No. 70-6 dated December 18, 1978, issued by the Department of National Revenue, Taxation and are binding provided the proposed transactions are completed before April 30, 1990.
Yours truly,
B.W. DathDirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch