| September 25, 1989 | |
| Current Amendments and | Business and General |
| Regulation Division | Division |
| R.B. Day | |
| B. Bryson | 957-2136 |
| Acting Director | |
| File No. 3-2567 |
Subject: 24(1)
We are writing with respect to our memorandum of September 5, 1989, and further to the comments in your response of September 8, 1989.
With respect to the issues raised in your response we advise as follows:
1. 24(1)
2. The issues in this case are similar to one recently submitted to the GAAR Committee. That committee expressed the view that arrangements that may circumvent the charitable donation limitations in 110.1 (1)(b) and 118.1(1) are not subject to 245(2).
In view of 2 above, and in view of the fact that 24(1) is, in fact and law, an agent of Her Majesty in Right of Province, we propose to issue a favourable ruling in this case.
We will hold this ruling in abeyance for two weeks pending receipt of your comments in this regard.
M.A. Hiltzfor Director GeneralSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch