January 2, 1990
| Mr. L. Farber | R.D. Weil |
| Director | (957-2066) |
| Tax Policy and Legislation Branch | F-3343 |
| Department of Finance | |
| 140 O'Connor Street | BY HAND |
| L'Esplanade Laurier | |
| 17th Floor, East Tower | |
| Ottawa, Ontario K1A 0H5 |
Dear Len:
Attribution Rules Subsection 74.5(7) of the Act
This is in reply to your letter of October 16, 1989 and further to our letter of October 31, 1989 to you on the same subject.
Where subsection 74.5(7) is applicable, the property loaned by the third party is deemed to have been loaned to the debtor by the guarantor for the purposes of, inter alia, subsection 74.4.
In order for section 74.4 to apply, one of the main purposes of the deemed loan must have been to reduce the income of the guarantor and to benefit the debtor.
21(1)(b)
Yours sincerely,
B.J. BrysonActing DirectorCurrent Amendments and Regulations DivisionRDW/