| September 20, 1989 | |
| TO - Publications Division | FROM - Specialty Rulings |
| Directorate | |
| Mr. R.C. Shultis | S.J. Tevlin |
| Director | 957-2118 |
| File No. 7-4326 |
SUBJECT: Interpretation Bulletin IT-59R3
We are writing to advise you of our concern regarding the comments in paragraph 3 of Interpretation Bulletin IT-59R3 as they relate to the "thin capitalization rules" as determined in subsection 18(4) of the Act.
24(1)
21(1)(a)
M.A. Hiltzfor Director GeneralSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch