| February 20, 1990 | |
| Vancouver District Office | Specialty Rulings |
| Chief of Audit | Directorate |
| P. Diguer | |
| Mr. E.D. Schneider | (613) 957-2123 |
| Audit Review Section | |
| File No. 5-9486 |
Re: Special Purpose Corporations
This is in reply to your memorandum of January 29, 1990 wherein you requested that we clarify, for a particular taxpayer, the Department's administrative concession with regards to the application of subsection 15(1) of the Act to a particular situation.
We have replied directly to the taxpayer, as requested, and attach a copy for your files.
for DirectorCorporate Reorganizations III SectionReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch