| 19(1) | File No. 5-9346 |
| S. Shinerock | |
| (613) 957-2108 |
February 6, 1990
Dear Sirs:
Re: Declaration of Dividends and their effect on the value of Preference Shares
We refer to your letter of December 28, 1989, in which you asked us to comment on the following situation.
24(1)
You have asked us to advise you whether the Department would have difficulty with this situation in either of the following two respects:
24(1)
Comments
It appears that your request relates to a specific situation in respect of which no proposed transactions are contemplated. We are unable to comment on the situation, since this would only be possible following a review of all the relevant facts pertaining to the situation. Also, as the responsibility for determining the tax consequences arising from actual completed transactions rests with the district taxation offices, the appropriate district taxation office may, upon disclosure of all relevant facts, be able to assist you in clarifying the tax consequences pertaining thereto.
Yours truly,
for DirectorReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch