9 March 1990 Ministerial Letter 74688 F - Attribution of Trust Income or Loss to Settlor of Trust

By services, 18 January, 2022
Official title
Attribution of Trust Income or Loss to Settlor of Trust
Language
French
CRA tags
75(2)
Document number
Citation name
74688
Severed letter type
Ministerial Letter
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633258
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-03-09 07:00:00",
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}
Main text
  DATE:  March 9, 1990
TO:  CALGARY  DISTRICT OFFICE FROM:  HEAD OFFICE
  Rulings Directorate
Attention:  Ross Brown Financial Institutions Section
Section Chief - Trust Section M.M. Trotier
  (613) 957-8957
  FILE No.  7-4688

SUBJECT: 24(1)

We have recently been advised by 19(1) that your district office will be reviewing the income tax returns of  24(1) and its related trusts.

We issued an advance income tax rulings with respect to 24(1) on August 12, 1988 and a supplementary ruling on December 23, 1988 (copies attached).  We had agreed at that time to write a memorandum to the relevant district office to comment on the application of subsection 75(2) of the Income Tax Act with respect to 24(1) only recently did 19(1)  advise us that Calgary is the appropriate District Office.  We are, therefore, enclosing the draft memorandum which we had proposed in September 1988 on this issue. 19(1) has indicated that the remission order for 1987 had not yet been requested.

We trust the attached will be of assistance.  Please do not hesitate to contact us if you have any questions.

ChiefFinancial Institutions  SectionFinancial Industries DivisionRulings Directorate