7 November 1990 Ministerial Letter 9028938 F - Distribute Property

By services, 18 January, 2022
Official title
Distribute Property
Language
French
CRA tags
159(2), 159(3), 150(3)
Document number
Citation name
9028938
Severed letter type
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632572
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-11-07 07:00:00",
"field_tags": []
}
Main text
  November 7, 1990
L.C. Tremblay Business and
Director General Division
Appeals and Referrals Division Bill Guglich
Appeals Branch (613) 957-2102
Attention: E. Short 8-902893

SUBJECT:  24(1)

This is in reply to your memorandum of October 16, 1990, concerning the application of subsections 159(2) & (3) to a court appointed receiver in a divorce proceeding.

24(1)

You requested our comments regarding the following unresolved issues:

1.     Must a responsible representative have control over all of the, property of a person in order for subsections 159(2) and (3) to apply?

2.     Has a "distribution" taken place? More specifically, were the  24(1)

Our Views

1.     Our views remain as stated in our letter dated July 31, 1986, (a copy of which was attached to your memorandum). It is our view that where the responsible representative does not have control of all the property of another person subsection 150(3) of the Act would not apply. However subsections 159(2) & (3) may apply even though the responsible representative does not have control over all the assets of the other person. Note the reference in subsection 159(2) to "a property ...... of another person".

2.     We agree that payments on account of a debt would not be considered distributions for purposes of subsections 159(2) & (3).

     24(1)     21(1)(a)      21(1)(b)

We trust this will be of assistance to you.

Your orange appeal file and reference material is enclosed.

R.J.L. ReadDirector GeneralRulings DirectorateLegislative and Intergovernmental Affairs Branch