30 October 1989 Internal T.I. 89M10009 F - Audit of Companies

By services, 18 January, 2022
Official title
Audit of Companies
Language
French
CRA tags
n/a
Document number
Citation name
89M10009
Severed letter type
Technical Interpretation - Internal
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633522
Extra import data
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"field_proprietary_citation": [],
"field_release_date_new": "1989-10-30 07:00:00",
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Main text

TELEX MESSAGE

  Date: Oct. 30, 1989
  Originator: David R. SenĂ©cal
  Branch: Legislation
  Building:  MacDonald Bldg.
  Room #: 1000
  Tel: 957-2074

Other Destination: Netherlands #33141 mifi n1

Message: Please see Telex Message Attached.

19(1)

1986-88 Canadian Tax returns of above companies currently under audit by our Department. Areas of particular concern include change of residency from Panama to the Netherlands in 1984, characterization of gains realized on immovable property situated in Canada and existence of permanent establishment in Canada.

24(1)

We therefore seek your permission for Messrs. William Rosenberger and Paul Fusco to visit taxpayers for purposes outlined during period December 11-15, 1989. Messrs. Rosenberger and Fusco would also like to meet with officials of your ministry to discuss the various issues.

Please advise by telex or telecopier (613) 957-7476 if you agree in principle. Formal request to follow.

C. Savage, A/DirectorProvincial and International Relations Division