18 July 1990 Administrative Letter 901146 F - Part XIII Tax on Interest Payments

By services, 18 January, 2022
Official title
Part XIII Tax on Interest Payments
Language
French
CRA tags
212(1)(b)
Document number
Citation name
901146
Severed letter type
Administrative Letter
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632004
Extra import data
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Main text
  July 18, 1990
Appeals Branch Financial Institution
Appeals and Referrals Division Section
  J.P. Dunn
  957-8961
Attn. W. Lynn
Section Chief 901146
  EACC9420

Section:  24(1)

We are writing in response to Dave Turner's memorandum of June 25, 1990 concerning the application of paragraph 212(1)(b) of the Income Tax Act (the "Act") 24(1)

It is our opinion that, in the circumstances described in your correspondence, Part XIII of the Act is applicable to the interest payments.

We are enclosing, for your perusal, a copy of our reply to Special Audits Division regarding similar situations.

We trust that our comments are of assistance to you.

for DirectorFinancial Industries DivisionRulings Directorate