| 24(1) | 5-901705 |
| D.S. Delorey | |
| (613) 957-3495 |
Attention: 19(1)
October 5, 1990
Dear Sirs:
This is in reply to your letter of July 16, 1990 concerning the meaning of the term "registered labour-sponsored venture capital corporation" referred to in paragraph 6700(d) of the draft Income Tax Regulations (the "Regulations").
In particular, you ask if by virtue of paragraph 6700(d) of the draft Regulations the shares of your company would qualify for the purposes of the "additional foreign property room available under subparagraph 206(2)(c)(i) of the Income Tax Act (the "Act").
We are not able to respond to your query in the manner requested because proposed legislation is involved and our role is limited to interpreting existing legislation. However, we are able to comment to the following extent. We note that paragraph 6700(d) of the proposed Regulations reads as follows:
"a corporation that is at that time a registered labour-sponsored venture capital corporation within the meaning of section 204.8 of the Act".
"Section 204.8 of the Act" is legislation that is proposed in the Technical Bill introduced in July 1990. We are enclosing copies of the relevant Explanatory Notes issued in July 1990 by the Honourable Michael H. Wilson, Minister of Finance. Should you have further enquiries concerning this proposed legislation, we suggest that you contact officials of the Department of Finance at (613) 996-1160 or at the following address:
Department of FinanceTax Policy - Legislation DivisionL'Esplanade Laurier 140 O'Connor Street Ottawa, OntarioK1A 0L6
Enquiries under the Act concerning the registration of a corporation as a labour-sponsored venture capital corporation will be the responsibility of the Registration Directorate, whose address is:
Revenue Canada, TaxationRegistration Directorate 400 Cumberland Street Ottawa, Ontario K1A 0L8
We trust our comments are of assistance.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate