| September 25, 1989 | |
| Publication Division | Specialty Rulings Directorate |
| A.A. Cameron | |
| Mr. R. Shultis | 957-2115 |
| Director | |
| File No. 7-4361 |
Subject: Interpretation Bulletin IT-474R
We are forwarding a photocopy of our recent reply to a request for a technical interpretation concerning the ability of a corporation formed on an amalgamation (Amalco) to file an election pursuant to subsection 85(7) of the Act with regard to a prior transfer of assets involving a predecessor corporation. We are also enclosing a photocopy of a legal opinion received with regard to this matter.
In our view that opinion we have expressed is consistent with the position adopted concerning Amalco's ability to file a notice of objection or to appeal an assessment with regard to a predecessor corporation as stated in paragraph 35 of Interpretation Bulletin IT-474R.
Consideration should be given to adding a comment on this point in an amendment to Interpretation Bulletin IT-474R.
M.A. Hiltzfor Director GeneralSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch