27 November 1989 Ruling 941221 F - Disposition of Taxable Canadian Property

By services, 18 January, 2022
Official title
Disposition of Taxable Canadian Property
Language
French
CRA tags
n/a
Document number
Citation name
941221
Severed letter type
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
631677
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1989-11-27 07:00:00",
"field_tags": []
}
Main text
  November 27, 1989
Mr. Keith Hillier Provincial and International
A/Director Relations Division
Non-Residential Taxation Division A. Watson
  957-2072
Attention:  George Lalonde
  HBW 9412-21

Disposition of Taxable Canadian Property By a Foreign Government

We have enclosed a copy of a letter dated November 16, 1989, and attachments thereto, concerning the disposition of a taxable Canadian property owned by the 24(1) and administered by the 24(1).  The solicitors for the 19(1) are requesting exemption from any Canadian tax of the disposition of taxable Canadian property in accordance with the Vienna Convention on Diplomatic Relations.

From our review of this request we are satisfied based on the confirmation by the New Zealand High Commissioner that the property relates to a government function and an exemption from tax may be granted under the Doctrine of Sovereign Immunity.

We hope that this is sufficient for your purposes.

C. SavageA/DirectorProvincial and International Relations Division

Enclosure

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