| 19(1) | File No. 5-9669 |
| J.P. Dunn | |
| (613) 957-8961 |
June 25, 1990
Dear Sir:
Your correspondence of February 7, 1990 addressed to the Toronto District Office has been forwarded to us for reply.
Your enquiry was with respect to the definition of the investment allowance of a corporation pursuant to draft subsection 181.2(4) of the Income Tax Act relating to the proposed Part I.3 Tax on Large Corporations.
It is our opinion that the assets referred to in draft subsection 181.2(4) are not restricted to such instruments issued by Canadian corporations but would include those issued by foreign corporations. We would further note that the terms "financial institution" and "long-term debt" are defined terms pursuant to draft subsection 181.1(1) of the Income Tax Act while special rules are provided in draft subsection 181.2(5) for the determination of the carrying value of an interest in a partnership as described above.
We would also advise that the opinions expressed above are based upon the amendments to the Income Tax Act proposed in Bill C-28 as passed by the House of Commons on December 20, 1989. Further, while we trust that our comments are of assistance to you, they do not constitute an advance income tax ruling and are, therefore, not binding upon the Department in respect of a particular situation.
Yours truly,
F. Lee Workman for DirectorFinancial Industries DivisionRulings Directorate