| 19(1) | File No. 5-8621 |
| D.S. Delorey | |
| (613) 957-3495 |
October 19, 1989
Dear Sirs:
This is in reply to your letter of August 30, 1989 concerning the proposed settling of a deceased's estate.
Your query relates to a specific proposed transaction. As indicated in paragraph 23 of Information Circular 70-6R, the Department does not provide written opinions with respect to such transactions other than as a reply to an advance income tax ruling request. We are prepared to consider the matter further should you decide to request an advance income tax ruling in the manner set out in that Circular. This would afford us the opportunity of reviewing the will and any other related documents so that we might address your concerns with some degree of certainty.
We do at times offer general comments that might assist taxpayers in determining the income tax implications inherent in a particular transaction. However, we find in this instance that any such comments would no be of further assistance to you inasmuch as they would essentially repeat those comments contained in Interpretation Bulletin IT-305R3 which, as indicated in your letter, you have already considered.
We regret not being able to further assist you at this time.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate