| November 2, 1989 | |
| Provincial and International Relations | Specialty Rulings |
| Division | Directorate |
| C. Savage, Director | J.E. Harms |
| 957-2109 | |
| Jim Wilson | |
| File No. 5-8379 |
Subject: 19(1) Flow-through of British Columbia Venture Capital Tax Credits ("VCT Credits") on amalgamation or winding-up
In our telephone conversations (Clark/Savage and Harms/Wilson) we agreed that the communications with the British Columbia Commissioner for Taxation (the "Commissioner") regarding the issues raised by 19(1) as well as the response to be given to 19(1) should come from the Provincial and International Relations Division rather than from the Specialty Rulings Directorate. Accordingly, we enclose herewith:
1. the letter from 19(1) dated July 10, 1989;
2. our initial contact letter dated July 20, 1989;
3. a draft response to 19(1) which is intended for review by the Commissioner prior to its release;
4. a draft letter to the commissioner; and
5. various file memos and copies of the relevant legislation and case law and our handwritten notes.
If you have any questions arising from the enclosed materials, please contact Jake Harms at 957-2109.
M.A. Hiltzfor Director GeneralSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch