| 19(1) | File No. 5-8965 |
| D.S. Delorey | |
| (613) 957-3495 |
November 24, 1989
Dear Sirs:
This is in reply to your letter of October 24, 1989 concerning the Special Release to Interpretation Bulletin IT-255R.
IT-255R dated May 21, 1985 explains the relationship between particular deeming provisions contained in section 144 of the Income Tax Act (the "Act") and the deduction previously available under section 110.1 of the Act as it read applicable to pre-1988 taxation years. With the repeal of section 110.1 as it then read, the relationship explained in IT-255R was no longer relevant after the 1987 taxation year. The Special Release to IT-255R was published for that reason.
As previously indicated, the flow-through concepts referred to in IT-255R relate to specific deeming provisions of the Act set out in subsections 144(4) and 144(8.2) (interest). Thus, the comments in IT-255R with respect to those deeming provisions remain valid. Similar comments are also set out in paragraphs 4 and 6 of IT-379 and paragraphs 68 and 69 of Information Circular 77-1R3.
We trust the above comments will be of assistance to you.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate