| 19(1) | File No. 5-8888 |
| C. Robb | |
| (613) 957-2744 |
October 26, 1989
19(1)
We are writing in response to your letter of October 11, 1989, wherein you request a technical interpretation with respect to arrangements between 24(1) and purchasers of condominium units.
The facts in your letter appear to relate to actual proposed transactions. Accordingly, your request should take the form of an advance income tax ruling. Therefore, we are unable to comment on the income tax consequences of the transactions you described.
The Department would be prepared to consider these transactions in the context of an advance income tax ruling request.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate