19 September 1989 Internal T.I. 57947 F - Request: Advance Income Tax Ruling

By services, 18 January, 2022
Official title
Request: Advance Income Tax Ruling
Language
French
CRA tags
n/a
Document number
Citation name
57947
Severed letter type
Technical Interpretation - Internal
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
631054
Extra import data
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"field_proprietary_citation": [],
"field_release_date_new": "1989-09-19 08:00:00",
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Main text
19(1) File No. 5-7947
  G.R. White
  (613) 957-8585

Attention:

September 19, 1989

Dear Sirs:

Re: 24(1)

We are writing in reply to your request dated April 18, 1989, for an advance income tax ruling concerning 24(1)

As expressed at paragraph 6 of Information Circular 70-6R, dated December 18, 1978, advance income tax rulings are given only in respect of proposed transactions. They are not issued with respect to transactions that are completed or a series of transactions that are significantly advanced prior to the issuance of the ruling. 24(1)

However, we do hereby express an opinion on the matter which is not binding on the Department.

Facts

Our understanding of the relevant facts is as follows:

24(1)

OPINION

In our opinion, expenses incurred in respect of the 24(1)

Yours truly,

DirectorBilingual Services and ResourceIndustries DivisionRulings Directorate