| 19(1) | File No. 5-7845 |
| A.A. Cameron | |
| (613) 957-2115 |
September 25, 1989
Dear Sirs:
Re: Subsection 85(7) of the Income Tax Act (the Act)
We are writing in response to your letter of March 16, 1989 in which you requested our views as to whether a corporation formed upon an amalgamation under subsection 87(1) of the Act (Amalco) would be able to file an election pursuant to subsection 85(7) of the Act with respect to transactions of the predecessors corporations.
In our view Amalco would be able to file the above-mentioned election, provided that under the relevant corporate statute governing the amalgamation, the predecessor corporations are continued in Amalco.
As explained in paragraph 24 of the Information Circular 70-6R any written or verbal opinions are not rulings and are not binding upon Revenue Canada, Taxation in respect of any taxpayers.
Yours truly,
for DirectorReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch