16 November 1990 Administrative Letter 902926 F - Amount Owing by Canadian Resident to Resident of Foreign Country Where No Tax Treaty

By services, 18 January, 2022
Official title
Amount Owing by Canadian Resident to Resident of Foreign Country Where No Tax Treaty
Language
French
CRA tags
78
Document number
Citation name
902926
Severed letter type
Administrative Letter
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
630964
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-11-16 07:00:00",
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Main text
24(1) 902926
  G. Arsenault
  (613) 957-2126

19(1)

November 16, 1990

Dear Sir:

This is in reply to your letter dated October 18, 1990 respecting section 78 of the Income Tax Act (the "Act").

In our opinion the filing of an agreement pursuant to paragraph 78(1)(b) of the Act in respect of an unpaid amount owing by a Canadian resident debtor to a non-resident creditor residing in a country with which Canada does not have a tax treaty would not in and of itself result in the non-resident creditor being considered to carry on business in Canada.

The opinion expressed herein is not an advance income tax ruling and, in accordance with paragraph 21 of information Circular No. 70-6R2 dated September 28, 1990, is not considered binding on the Department.

Yours truly,

for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and IntergovernmentalAffairs Branch