29 August 1991 External T.I. 9123585 F - Determination of Fair Market Value of Preferred Shares

By services, 18 January, 2022
Official title
Determination of Fair Market Value of Preferred Shares
Language
French
CRA tags
85(1)(e.2),
Document number
Citation name
9123585
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
630768
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1991-08-29 08:00:00",
"field_tags": []
}
Main text

5-912358

Dear Sirs:

Re: Our letter of August 23, 1991 (the "Letter")

24(1)

We are writing in response to your request of August 26, 1991 that we reconsider our reply to question #3 as described in the Letter:

24(1)

Comments

24(1)               

it was our position that paragraph 85(1)(e.2) of the Act would be applicable.

Although, as described in subparagraph 14(f) of Information Circular 70-6R2 dated September 28, 1990 issued by Revenue Canada, Taxation ("IC 70-6R2"), we are unable to provide any comments on the determination of fair market value, it is our view that the fair market value of the preferred shares may be maintained if the outstanding balance was charged an interest rate which reflected fair market value.

The comments expressed are not advance income tax rulings and are not considered binding on the Department, in respect of any taxpayer, in accordance with paragraph 21 of IC 70-6R2

Yours truly,

for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch