| 19(1) | File No. 5-9561 |
| A.B. Adler | |
| (613) 957-8962 |
February 22, 1990
Dear
This is in reply to your letter dated January 31, 1990 and is further to ours of November 1, 1988, in which you requested our advice concerning our advice concerning the course of action 24(1)
Our role is interpretive rather than advisory and, accordingly, we are not in a position to provide you with the advice you requested. However, since the transactions in question are completed transactions it would be appropriate for you to discuss the income tax implications of those transactions with relevant officials at your local district taxation office.
We regret our response could not be favourable.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate