| September 1, 1989 | |
| Roy C. Shultis, Director | Specialty Rulings |
| Publications Division | Directorate |
| Legislative Affairs Directorate | S. Leung |
| 957-2116 | |
| Attention: T. Bryant |
Subject: Interpretation Bulletin Project Number 1963 Revision of IT-146R3
This memorandum is in response to yours dated August 16, 1989.
Our comments on version 5 of the above-noted Project (the "Project") are as follows:
1. We feel that paragraph 7 of IT-146R3 is still applicable and we wonder why it was not included in the Project. We suggest that the paragraph be included immediately after paragraph 3 of the Project and the words "subsection 26(24) of the Income Tax Applicable Rules, 1971 ITAR" be added in the "Reference" section of the Project immediately following the words "paragraph 89(1)(j)".
2. We assume that IT-66R6 as noted in paragraph 6 of the Project will be published and distributed prior to the publication of the Project. Otherwise it would not be appropriate to refer to that IT in paragraph 6 of the Project.
21(1)(b)
We have also suggested other minor editing changes to the Project for your consideration as noted thereon. The adjusted Project is herewith enclosed.
M.A. Hiltzfor Director GeneralSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch