| August 1, 1990 | |
| VANCOUVER DISTRICT OFFICE | HEAD OFFICE |
| S. McKenzie | Financial Industries Division |
| Chief of Audit | T. Murphy |
| (613) 957-2747 | |
| EACC9356 | |
| 3-901514 |
SUBJECT: Advance Income Tax Ruling 24(1)
We recently considered an advance income tax ruling request (copy attached) 24(1)
While we refused to rule on this proposed transaction described in the ruling request, it is possible that 24(1) and 24(1) may proceed with the same or similar transaction without an advance income tax ruling.
We have enclosed for your files a description of the proposed transaction and our views on the application of the Act to the said transaction. They are contained in the attached copies of our reply to the taxpayers' representative and our Statement of Principal Issues.
ChiefLeasing and Financing SectionFinancial Industries DivisionRulings Directorate