| 19(1) | File No. 900393 |
| W.C. Bailey | |
| 957-2061 |
May 22, 1990
19(1)
Re: Proposed Land Purchase
This will reply to your letter of April 6, 1990 in which you request our interpretation of the tax implications regarding a proposed land acquisition.
In the situation you describe, it may be possible to obtain the tax results you contemplate. However, we are unable to confirm those results without access to a copy of a proposed trust agreement wherein the corporation will hold the three lots in trust for the individuals.
The situation described being a proposed transaction apparently involving an actual taxpayer, we would suggest that if you wish to pursue this matter further that you proceed by way of our advance ruling procedure as set out in Information Circular 70-6R. If you do, it will be necessary to submit a copy of the proposed trust agreement. In the event that the transaction has been completed, please direct your further inquiries to the local District Taxation Office.
We regret that we cannot comply with your request as submitted.
Yours sincerely,
DirectorBusiness and General Division Specialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch