| 19(1) | File No. 5-8959 |
| J. Chan | |
| (613) 952-9019 |
November 30, 1989
Dears Sirs:
Re: Request for Technical Interpretation
We are writing in reply to your letter dated October 16, 1989, wherein you requested a technical interpretation of the income tax consequences of the proposed winding up of 24(1) and 24(1) pursuant to the provisions of subsection 88(1) of the Income Tax Act.
We have considered the issues raised in your letter and have concluded that the proposed transactions and issues on which you requested our technical interpretations are of such complexity that we are only prepared to deal with them on an advance income tax ruling basis. In accordance with paragraph 23 of the Information Circular 70-6R dated December 18, 1978 (IC 70-6R), written opinions concerning proposed transactions of a complex nature will not be given.
As explained at paragraph 6 of IC 70-6R, however, we are prepared to consider advance income tax rulings in respect of proposed transactions of a complex nature, provided that they are seriously contemplated and are not of a hypothetical nature.
We refer to the procedures outlined in IC 70-6R in the event that you wish to request an advance income tax ruling.
Yours truly,
Section ChiefResource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate