22 February 1990 Administrative Letter F3546 F - Shareholder's Benefit

By services, 18 January, 2022
Official title
Shareholder's Benefit
Language
French
CRA tags
15(1)
Document number
Citation name
F3546
Severed letter type
Administrative Letter
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
629826
Extra import data
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"field_release_date_new": "1990-02-22 07:00:00",
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Main text
  February 22, 1990
Mr. M.A.G. Hiltz Current Amendments and
Director Regulations Division
Specialty Rulings Wm. R. McColm
  957-2068
  File No. F-3546

Subsection 15(1)

The Department of Finance has written, a copy of their letter is attached, asking for an interpretation of subsection 15(1) of the Income Tax Act in a particular fact situation they describe.

In addition to the facts described in their letter, we have been told to assume that there was only one class of shares, there were no V-Day value considerations involved, and the transaction was not tax motivated.

May we have your comments.  In our view subsection 15(1) would not apply in the circumstances described.

B.J. BrysonActing DirectorCurrent Amendment and Regulations Division

Attach.

WmRMcC/jab