| 24(1) | 900277 |
| J.E. Harms | |
| (613) 957-2109 |
Attention: 19(1)
October 11, 1990
Dear Sirs:
Re: 24(1) Request for advance income tax ruling
We are writing in response to your letter of March 26, 1990 in which you requested that we provide certain advance income tax rulings in respect of the proposed transactions described therein. In the course of our ensuing telephone conversations (Harms 19(1) we raised a number of issues arising out of the proposed transactions. We advised you that we cannot at this time provide you with the requested rulings because the eligibility of the parties to certain proposed transfers of shares of the above corporations to elect pursuant to subsection 85(1) of the Income Tax Act (Canada) in respect of the transfers of such property, a central issue in the context of the proposed transactions, involves an issue that is before the courts.
We understand that, due to the uncertainty of the tax consequences of the proposed transactions, your clients are not proceeding with the proposed transactions at this time. We therefore consider your ruling request to have been withdrawn and are closing your file accordingly. A bill for the time spent in considering your request will be forwarded under cover of a separate letter. As discussed, if the central issue is finally determined in your clients' favour and your clients wish to proceed with the proposed transactions, we would be pleased to reconsider the proposed transactions upon receipt of a new request.
Yours truly,
for DirectorReorganizations and Non-resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch