| 19(1) | File No. 5-8913 |
| R.B. Day | |
| (613) 957-2136 |
November 21, 1989
19(1)
We are writing in reply to your letter of July 12, 1989, and further to your follow-up letter of October 2, 1989, wherein you requested our views regarding the application of section 149.1 of the Income Tax Act where a Charitable organization and /or registered charity (the "registered entity") is a fifty percent partner in a marketing venture in Canada.
24(1)
You have posed the following questions with regard to the above- noted registered entity.
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Our Comments
Interpretation Bulletin IT-90 defines, in paragraph 2 thereof, a partnership as
"the relation that subsists between persons carrying on business in common with a view to profit."
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In response to your specific questions, there is no specific provision in the Act that sets out guidelines regarding qualified investments for a charitable organization or a public foundation. Paragraph 149.1(1)(e.1) does, however, define a "non-qualified investment" for a private foundation.
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We apologize for the long delay in replying to your enquiry.
Yours truly,
for DirectorReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch