| 24(1) | 5-902935 |
| Bill Guglich | |
| (613) 957-2102 |
19(1)
November 21, 1990
Dear Sirs:
This is in reply to your letter of October 16, 1990, concerning the availability of a mortgage reserve where the original due date of the mortgage has been extended. You have made reference to the fact that the comments which were in paragraphs 9 & 10 of IT-436 were not included in IT-436R.
The comments in paragraphs 9 & 10 of IT-436 were not included in IT-436R as it was considered that they would have limited application since subsection 20(8) and subparagraph 40(1)(a)(iii) of the Act had been amended to restrict the time limit to 36 months and 5 years respectively for the deduction of reserves. However, our comments in paragraphs 9 & 10 of IT-436 remain valid provided all the requirements of the Act are otherwise met.
We trust this will be of assistance to you.
Yours truly,
for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch