25 October 1990 Ministerial Correspondence 902444 F - Transfer of Property to Corporation by Shareholder

By services, 18 January, 2022
Official title
Transfer of Property to Corporation by Shareholder
Language
French
CRA tags
85(1)(c.1)
Document number
Citation name
902444
Severed letter type
Ministerial Correspondence
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
631894
Extra import data
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"field_proprietary_citation": [],
"field_release_date_new": "1990-10-25 08:00:00",
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Main text
24(1) 902444
  M.P. Sarazin
  (613) 957-2125

19(1)

October 25, 1990

Dear Sirs:

Re:  Paragraph 85(1)(c.1) of the Income Tax Act (Canada) (the "Act")

We are writing in response to your letter dated September 7, 1990 in which you requested a technical interpretation on the application of paragraph 85(1)(c.1) of the Act to the following hypothetical situation.

Facts

24(1)

In your letter you have outlined an actual fact situation related to a past transaction. The review of such transactions falls within the responsibility of District Taxation Offices. In our telephone conversation of October 19, 1990 (19(1) Sarazin) you indicated that this matter had recently been reviewed one of the District Taxation Offices and that a reassessment has been issued. Accordingly, we do not believe that it would be appropriate for us to comment on this matter at this time.

Yours truly,

for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch