19 January 1990 External T.I. 59395 F - Transfer of Retiring Allowances

By services, 18 January, 2022
Official title
Transfer of Retiring Allowances
Language
French
CRA tags
60(j.1), 89(1) Canadian corporation, 251(2)(c)
Document number
Citation name
59395
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
630479
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-01-19 07:00:00",
"field_tags": []
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Main text
19(1) File No. 5-9395
  A.B. Adler
  (613) 957-8962

January 19, 1990

Dear Sirs:

This is in reply to your letter dated January 11, 1990, and is further to ours of October 11, 1989, concerning the application of paragraph 60(j.1) of the Income Tax Act ("Act") to an actual situation.

As indicated in our previous letter we are only in a position to provide you with our general comments.

A foreign corporation and a Canadian Corporation (within the meaning assigned by paragraph 89(1)(a) of the Act) that have a common parent corporation are related persons by reason of paragraph 251(2)(c) of the Act.  Accordingly, the foreign corporation could be "a person related to the employer" for purposes of subparagraph 60(j.1)(ii) of the Act.

We trust our comments are sufficient for your purposes.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate