| January 11, 1990 | |
| APPEALS BRANCH | Specialty Rulings |
| R.J. Angus | Directorate |
| Appeals and Referrals Division | C. Tremblay |
| (613) 957-2095 | |
| File No. 8-0339 |
Subject: Restricted Farm Losses
This is in reply to your memorandum of December 11, 1989 requesting a review and our comments of your draft reply on the objective of subsection 31(1). Since, as you indicated, the replies you have drafted will be a statement of Departmental understanding binding on the Minister, we have taken the liberty of sending your response to Current Amendments for their views and comments.
We concur with your proposed answers. However, we find it surprising that our Minister's understanding of the purpose of section 31 would be considered relevant either to the validity of the assessment or to the validity, in light of the Charter of Rights and Freedoms, of the legislation itself.
B.W. DathDirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch