8 August 1990 External T.I. 9014505 F - Tax Treatment of the Partition of Immovable Properties

By services, 18 January, 2022
Official title
Tax Treatment of the Partition of Immovable Properties
Language
French
CRA tags
248(20)
Document number
Citation name
9014505
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632182
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-08-08 08:00:00",
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Main text
19(1) 5-901450
  G. Pelletier
  (613) 957-8953
  EACC9342

August 8, 1990

Dear Sirs:

We are writing in response to your letter of June 20, 1990 in which you asked whether we were prepared to provide an advance income tax ruling regarding the tax treatment of the partition of certain immovable properties located in  24(1)  owned in indivision.

The Minister of Finance had released on July 13, 1990 draft legislation relating to the Income Tax Act and related statuses.  It is proposed to add a new subsection 248(20) to the Income Tax Act to clarify the tax consequences of the partition of property previously owned jointly by two or more persons.

We will be prepared to give a ruling on this new subsection when the proposed amendments will be received the Royal Assent.

In the meantime, we are only in a position to give opinions on that new subsection.

Yours truly,

For Acting DirectorBilingual Services and ResourceIndustries DivisionRulings Directorate