| September 28, 1990 | |
| Technical Publications Division | Rulings Directorate |
| Resource Industries | |
| Roy C. Shultis | Section |
| Director | Allan Nelson |
| 957-8984 | |
| 7-900253 | |
| EACC9611 |
Subject: Publication of Advance Tax Ruling 24(1) File #3-2679, Dated December 22, 1989
Enclosed, as requested, is a draft of the 24(1) ruling previously recommended for publication.
This draft was prepared in accordance with the instructions contained in the August 8, 1990 memo from R.J.L. Read, then Acting Assistant Deputy Minister concerning the subject "Publication of Advance Tax Rulings".
We have edited the 24(1) ruling extensively in order to delete non-substantive facts and issues in the ruling which would have little or no relevance to more than a few taxpayers. 21(1)(b)
The single issue presented in the enclosed draft ruling for publication was dealt with at the December 21, 1989 meeting of the Review Committee.
It is our view that our position on this issue could be of interest to a large number of taxpayers.
If you have further queries on this file please contact the writer.
Acting/Director Bilingual Services and Resource Industries DivisionRulings Directorate