| November 27, 1989 | |
| Sudbury T.C. | Head Office |
| TPS 1-3 | Financial Industries Division |
| Mae Stech | W.C. Harding |
| Unit Head | (613) 957-3499 |
| File No. 7-4475 |
Subject: Transfer of a Refund of Premiums 60(1) of the Income Tax Act (the "Act")
This is in reply to your memorandum of October 27. 1989 in respect of the 24(1)
Facts:
Pursuant to your memo and a telephone conversation of November 10, 1989 (Harding/Stech) we understand the relevant facts of this case to be:
24(1)
Our Opinion:
Based on our understanding of the facts as detailed above, it is our opinion that:
24(1)
for DirectorFinancial Industries DivisionRulings Directorate