5-903540
Dear Sirs:
Re: Request for Technical Interpretation
We are responding to your letter, dated December 6, 1990, in which you requested a technical interpretation regarding the applicability of sections 84.1 and 245 and subsection 55(2) of the Income Tax Act (the "Act") to two situations outlined in your letter.
As we noted in our telephone conversation on December 21, 1990, McCarron-McGuire), it appears that the two situations outlined in your letter relate to specific proposed transactions. Since assurance as to the tax consequences of specific proposed transactions will only be given in response to a written request for an advance income tax ruling, we will not be providing you with any written comments on the applicability of the above-noted provisions of the Act to the situations described.
We would be pleased to consider an advance ruling request in the future, should one be required. The procedures for requesting advance income tax rulings are set out in Information Circular 70-6R2, dated September 28, 1990.
Yours truly,
for DirectorReorganizations and Non-resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch