Re: Incorporation of Legal Practices
This is in reply to your letter of March 6, 1991, and further to a telephone conversation of April 3, 1991 (19(1) Tremblay), wherein we discussed the department's position in respect of a request for a ruling where the legislation has not yet been passed. We confirm that, since Ontario Legislature Bill 45 has not been proclaimed into law, we cannot issue a ruling that is based on a proposed transaction awaiting it's enactment. However, if you have general concerns and wish our views regarding transfers of assets from a partnership or a proprietorship to a corporation using section 85 of the Income Tax Act, we suggest you write to us for our comments.
Yours truly,
for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch