| 19(1) | 3-3723 |
| M. Eisner | |
| (613) 957-2138 | |
| December 6, 1989 |
Dear Sirs:
Re: 24(1) Advance Income Tax Ruling
As you advised us in your letter of October 22, 1989, that you wish to withdraw your ruling request made on behalf of the above-noted taxpayer, we are closing our file.
An invoice for the time spent reviewing the advance income tax ruling request will be sent to you under separate cover.
An additional matter concerns your letter of October 20, 1989, in which you asked us to comment on the situation where a cooperative corporation, acting in the capacity or an agent for its members as outlined in IT-493, utilizes a sub-agent (a corporation) to acquire and carry on a business. In such circumstances, it is our general view that the incomes or losses therefrom are incomes or losses of the members rather than the agent or sub-agent.
We trust you will find the foregoing satisfactory.
Yours truly,
B.W. DathDirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch