| 19(1) | 5-8745 |
| Bill Guglich | |
| (613) 957-2102 | |
| December 4, 1989 |
Dear Sirs:
Re: 24(1) Advance Income Tax Ruling 3-2459
This is in reply to your letter of September 19, 1989 wherein you requested an extension of time until at least December 31, 1990 for the completion of the proposed transactions outlined in Advance Income Tax Ruling 3-2459 dated August 25, 1989.
24(1)
Rulings Given
Provided that your above statement when taken together with the statements of facts and proposed transactions set out in our rulings dated August 25, 1989 is accurate and constitutes complete disclosure of all relevant facts and proposed transactions we rule that your request for an extension of time until December 31, 1990 for completion of the loan transactions does not affect our rulings given in our letter of August 25, 1989.
This ruling and the rulings given in our letter of August 25, 1989 are subject to the general limitations and qualification set out in our Information Circular 70-6R dated December 18, 1978 issued by the Department of National Revenue, Taxation and are binding provided the proposed transactions are completed before December 31, 1990.
Yours truly,
B.W. DathDirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch