28 February 1991 Internal T.I. 9102347 F - Application of GAAR to a Cross-Border Purchase Butterfly Reorganization

By services, 18 January, 2022
Official title
Application of GAAR to a Cross-Border Purchase Butterfly Reorganization
Language
French
CRA tags
245(2)
Document number
Citation name
9102347
Severed letter type
Technical Interpretation - Internal
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632953
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1991-02-28 07:00:00",
"field_tags": []
}
Main text

7-910234

Subject: Publication of Advance Income Tax Ruling 1-957 (the "Ruling")

In your memorandum of January 23, 1991, you requested our views regarding the suitability of the Ruling for publication.  The main issue in the Ruling involves the application of subsection 245(2) of the Income Tax Act to a cross-border purchase butterfly reorganization.  While we may have original recommended that the Ruling be published, the main issue in the Ruling has since been dealt with in a number of other rulings that have been or are being prepared for publication.  Therefore, in our view, publication of the Ruling is no longer necessary or advisable.

DirectorReorganizations and Non-resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch