| 19(1) | File No. 1-765 |
| K.J. Donnelly | |
| (613) 957-3500 |
June 14, 1989
Dear Sirs:
Re: Advance Income Tax Ruling Request 24(1)
We are writing in response to your letters of January 22, 1988 and February 16, 1988 requesting that we rule on the deductibility under paragraph 20(1)(c) of the Income Tax Act, of certain payments characterized as interest on proposed Subordinated Debentures to be issued in 1990.
In accordance with subparagraph 14(1) of Information Circular 70-6R issued by Revenue Canada, Taxation we regret that we are unable to give any ruling on the above-noted 20(1)(c) issue as the determination is primarily one of fact and the circumstances of this case are such that all of the pertinent facts cannot be established at this time.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate