| 19(1) | 5-9117 |
| A.A. Cameron | |
| (613) 957-2115 |
December 22, 1989
Dear Sirs:
Re: Request for a Technical Interpretation
We are writing in response to your letter of November 20, 1989 in which you have requested our views with regard to a fact situation which you described.
The facts stated in your letter would appear to relate to a situation involving actual taxpayers. Confirmation as to the tax consequences of such transactions are only given in advance income tax rulings requested in accordance with the guidelines contained in Information Circular 70-6R dated December 18, 1978. Therefore, we are unable to comment on the fact situation outlined therein.
Yours truly,
for DirectorReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch