1 June 1990 Ruling 59451 F - Non-resident Business Income Losses

By services, 18 January, 2022
Official title
Non-resident Business Income Losses
Language
French
CRA tags
115(1)
Document number
Citation name
59451
Severed letter type
Ruling
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632283
Extra import data
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"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-06-01 08:00:00",
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Main text
24(1) File No. 5-9451
  G. Arsenault
  (613) 957-2126

19(1)

June 1, 1990

Dear Sirs:

Re: Non-Resident Business Income Losses

This is in reply to your letter dated January 16, 1990.

We concur with your interpretation that losses that are allowable business investment losses realized by an individual during a taxation year throughout which he was a non-resident of Canada from the disposition of a share of the capital stock of a Canadian controlled private corporation that is a small business corporation or from the disposition of a debt owing to the taxpayer by such a corporation will not be deductible pursuant to subsection 115(1) notwithstanding that such losses also constitute capital losses.

We have brought this matter to the attention of the Department of Finance. You may also wish to communicate your views to the Department of Finance.

Yours truly,

for DirectorReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch