| DATE October 17, 1989 | |
| TO Toronto District Office | FROM Specialty Rulings |
| Directorate | |
| Mr. G.A. Troy | D.Y. Dalphy |
| Chief of Audit | (613) 957-2117 |
| File No. 7-3781 |
SUBJECT: 24(1) Request for an Advance Income Tax Ruling
We enclose copies for your reference, of correspondence in respect of the above-noted corporation. Their request for an advance income tax ruling was withdrawn since we were unable to provide a favourable advance income tax ruling.
It is our view that, if the taxpayers proceed with the proposed transactions, capital gains will arise. If you require any assistance on this matter, please do not hesitate to contact us.
K.H. MajorChiefForeign SectionReorganizations and Non-ResidentsSpecialty Rulings directorateLegislative and intergovernmentalAffairs Branch