13 November 1990 Ruling 901891A F - Intercorporate Dividends

By services, 18 January, 2022
Official title
Intercorporate Dividends
Language
French
CRA tags
55(3)(a), 55(2)
Document number
Citation name
901891A
Severed letter type
Ruling
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
630658
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-11-13 07:00:00",
"field_tags": []
}
Main text
24(1) 901891
  J. Teixeira
  (613) 957-2119

19(1)

November 13, 1990

Dear Sirs:

We are writing in reply to your letter of September 27, 1990, wherein you have expressed your opinion in regard to the particular situation which was described in our letter to you dated September 7, 1990.

Our opinion remains as stated in our letter of September 7, 1990. In your proposed transactions the provisions of paragraph 55(3)(a) of the Income Tax Act (the "Act") will not exempt the dividends received by Newcos 1 and 2 from the application of subsection 55(2) of the Act. Consequently, the requirements of paragraph 55(3)(b) of the Act will have to be satisfied.

Yours truly,

for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and IntergovernmentalAffairs Branch