| 24(1) | 900400 |
| G. Arsenault | |
| (613) 957-2126 | |
| Attention: 19(1) | EACC9330 |
August 10, 1990
Dear Sirs:
Re: Shareholders Benefits - Single Purpose Corporations
This is in reply to your letter dated April 6, 1990.
Our administrative policy regarding the application of subsection 15(1) to the holding of US residential real estate by a Canadian corporation for the benefit of its Canadian shareholder continues to be as stated in response to Question 20 at the Revenue Canada Round Table at the 1980 Canadian Tax Foundation Annual Conference as elaborated upon in response to questions at the 1985, 1987, 1988 and 1989 Conferences.
Our administrative policy is strictly limited to residential real property situated in the United States acquired for the personal use of the shareholder of the acquiring corporation and does not extend to club memberships.
Yours truly,
for DirectorReorganization and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch