18 June 1990 Ruling 900371 F - Contractual Estate Freeze

By services, 18 January, 2022
Official title
Contractual Estate Freeze
Language
French
CRA tags
54 disposition
Document number
Citation name
900371
Severed letter type
Ruling
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632810
Extra import data
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"field_proprietary_citation": [],
"field_release_date_new": "1990-06-18 08:00:00",
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Main text
19(1) File No. 900371
  P.W. Osborn
  (613) 957-2120

June 18, 1990

Dear sirs:

Re:  Contractual Estate Freeze - Your File 19(1)

We are writing in reply to your letter of April 11, 1990 in which you requested our opinion of the application of section 54 of the Income Tax Act to a pending series of transactions and events. As your enquiry deals with a fact situation your submission should be in the form of a request for an advance income tax ruling in accordance with the procedures set forth in Information Circular 70-6R dated December 18, 1978.

Yours truly,

for DirectorReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch