29 June 1990 Ruling 74811 F - Permanent Establishment

By services, 18 January, 2022
Official title
Permanent Establishment
Language
French
CRA tags
400(2)(f)
Document number
Citation name
74811
Severed letter type
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
630347
Extra import data
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"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-06-29 08:00:00",
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Main text
  June 29, 1990
C. Savage John Shaw
A/Director 957-8968
Provincial and International HBW 1231-2
Relations Division HBW 1231-6-3
  File No. 7-4811

Subject: Paragraph 400(2)(f) of the Regulations

Further to your memorandum of March 15, 1990, we agree that we, and  24(1)     thought it had to meet a more stringent test in obtaining our ruling 3-2702 than it in fact had to meet.  The matter is now wholly academic, as, for commercial reasons, 24(1) is unable to meet even the lesser test factually required by the law for the result it sought. 21(1)(b)

We expect  24(1) to make this point with Finance, if it has not already done so.

24(1)

A/DirectorBilingual Services & ResourceIndustries DivisionRulings Directorate