| 24(1) | File No. 901029 |
| M.M. Trotier | |
| (613) 957-8957 |
Attention: 19(1)
June 25, 1990
Dear Sirs:
This is in reply to your letter dated May 28, 1990 concerning your April 24, 1990 request for an advance income tax ruling which has since been withdrawn.
We can confirm that it is the taxpayer receiving and not the taxpayer paying an amount described in subsection 153(4) of the Income Tax Act that is required to make the remittance provided for in that subsection.
It is our view that to the extent subsection 153(4) of the Income Tax Act has application to 24(1) with respect to amounts received by it in prior years remittances should already have been made. In accordance with Information Circular Circular 70-6R, a copy of which is attached, we are unable to provide a ruling with respect to completed transactions. Questions concerning such transactions should be taken up with your Revenue Canada, Taxation District Office.
We hope this clarifies the reasons why we were not able to rule as requested.
Yours truly,
F. Lee WorkmanChiefFinancial Institution SectionFinancial Industries DivisionRulings Directorate