| 19(1) | File No. 5-8345 |
| Peter Lee | |
| (613) 957-2745 |
October 10, 1989
Dear Sir:
Re: Land Improvement
We are writing in reply to your letter of July 7, 1989, wherein you requested our opinion on the classification of expenditures with respect to developing the greens, tees and fairways of a golf course situated on leased land.
The classification of these expenditures can be determined only when all the details of the transactions, including the rights and obligations of the lessee and lessor, have been established and reviewed. However, we would only undertake such review on an advance income tax ruling basis set our in Information circular 70-6R dated December 18, 1978.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate