10 November 1989 Ruling 58953 F - Deemed Disposition by Trust

By services, 18 January, 2022
Official title
Deemed Disposition by Trust
Language
French
CRA tags
104(4)
Document number
Citation name
58953
Severed letter type
Ruling
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632075
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1989-11-10 07:00:00",
"field_tags": []
}
Main text
19(1) File No. 5-8953
  A.B. Adler
  (613) 957-8962

November 10, 1989

Dear Sirs:

This is in reply to your letter dated October 24, 1989, and is further to ours of October 16, 1989, regarding the application of subsection 104(4) of the Income Act ("Act") to your example.

In our view subsection 104(4) of the Act will not apply at the time of the death of the survivor of A and B in the example in out letter of October 16, 1989.

As indicated in paragraph 24 of Information Circular 70-6R our written opinions are not binding on this Department.  Should you wish to pursue this matter further we suggest that you request an advance ruling.

We trust that our comments are sufficient for your purposes.

Your truly,

for DirectorFinancial Industries DivisionRulings Directorate