5-902022
Dear Sirs:
Re: Auction Preferred Shares
We are writing in response to your letter of October 19, 1990 requesting our views on whether the hypothetical perpetual auction preferred shares having the terms and attributes described therein, which Canco proposes to issue, would be taxable preferred shares and term preferred shares as defined in subsection 248(1) of the Income Tax Act. We regret that other workload prevented an earlier reply.
As the proposed issuance of the perpetual auction preferred shares appears to involve an actual situation, we are unwilling to comment on the income tax implications arising from the issuance of such shares except in the context of an advance income tax ruling. The procedures for requesting a ruling are outlined in Information Circular 70-6R2.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate