3 October 1989 External T.I. 58525 F - Deemed Disposition Rule - Valuation of Shares of a Holding Company

By services, 18 January, 2022
Official title
Deemed Disposition Rule - Valuation of Shares of a Holding Company
Language
French
CRA tags
70(5)(a)
Document number
Citation name
58525
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632409
Extra import data
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"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1989-10-03 08:00:00",
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Main text
19(1) File No. 5-8525
  D.S. Delorey
  (613) 957-3495

October 3, 1989

Dear Sirs:

This is in reply to your letter of August 15, 1989 concerning the proper method of valuing shares of a holding company for the purpose of the deemed disposition rule in paragraph 70(5)(a) of the Income Tax Act.

As indicated in paragraph 14(h) of Information Circular 70-6R, the Department normally does not involve itself in fair market value determinations, other than to verify the correctness of determinations previously made by a taxpayer. Since the responsibility for making such verifications rests with the Department's valuators, we forwarded your letter to:

     Mr. K. Warren, Director Audit Applications Division Revenue Canada, Taxation 8th Floor 123 Slater Street Ottawa, Ontario K1A 0L8

We trust that the above comments will be of assistance.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate