17 August 1990 Internal T.I. 901499 F - Advance Income Tax Ruling

August 17, 1990

Dear Sirs:

Re:   Advance Income Tax Ruling 3-2438 dated June 23, 1990 (the "Ruling Letter") Paragraph 55(3)(a) of the Income Tax Act (The "Act")

We are writing in response to your letter of July 5, 1990 wherein you inquired whether we would favourably consider a request for an advance income ruling where                    24(1)

It is our understanding form our telephone conversation of July 31, 1990  19(1)   Leung) that the proposed transactions described in the Ruling Letter have been completed. As was discussed in our above noted telephone conversation, we would consider a request for a new advance income tax ruling in connection with the above mentioned matter provided that a full disclosure of the facts, proposed transactions and purpose of the proposed transactions in respect of new ruling request is made, as set out in Information Circular 70-6R.

Yours truly,

for DirectorReorganization and Non-Resident DivisionRulings Directorate Legislation and Intergovernmental Affairs Branch