14 December 1990 Administrative Letter 903296 F - Transfer of Property to Corporation by Shareholders

By services, 18 January, 2022
Official title
Transfer of Property to Corporation by Shareholders
Language
French
CRA tags
85(1), 110.6(1) qualified small business corporation share
Document number
Citation name
903296
Severed letter type
Administrative Letter
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632781
Extra import data
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Main text
24(1) 903296
  M.P. Sarazin
  (613) 957-2125

19(1)

December 14, 1990

Dear Sirs:

Re:  Subsection 85(1) of the Income Tax Act (Canada) (the "Act")

We are writing in response to your letter of November 19, 1990 wherein the situation described is identical to the one described in your letter of October 30, 1990 except for the additional statement that one share qualifies as a qualified small business corporation share, as that term is defined in subsection 110.6(1) of the Act, and the other does not qualify.

Notwithstanding this minor change to the situation described, our general position regarding this situation continues to be as reflected in our November 15, 1990 response to your original letter.

Yours truly,

for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch