8 November 1989 External T.I. I3240 F - Deduction on Current Basis of Mutual Fund Front-end Loading Fees by Limited Partnerships

By services, 18 January, 2022
Official title
Deduction on Current Basis of Mutual Fund Front-end Loading Fees by Limited Partnerships
Language
French
CRA tags
n/a
Document number
Citation name
I3240
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
631278
Extra import data
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"field_release_date_new": "1989-11-08 07:00:00",
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Main text

November 8, 1989

Mr. R.A. Short
General Director
Tax Policy and Legislation Branch Wm. R. McColm
Department of Finance 957-2068
140 O'Connor Street BY HAND
L'Esplande Laurier I-3240
16th Floor, East Tower
Ottawa, Ontario K1A 0G5

Dear Al:

Attached is a copy of memorandum received from our Specialty Rulings Directorate concerning the deduction of mutual fund front- end loading fees which are being paid for and deducted on current basis by limited partnerships.  In exchange for this service a partnership receives an income flow from the fund over a period of years which is based on a percentage of the net assets of the fund.

21(1)(b)

While they have already issued a favourable ruling on such an arrangements, this matter may be of interest to you.  If we can provide further information, please contact us.

Yours sincerely,

B.J. Bryson Acting DirectorCurrent Amendments andRegulations Division

WRMcC/jab