15 November 1990 External T.I. 9030505 F - Roll-over to Corporation in Respect of Shares which are Identical Properties

By services, 18 January, 2022
Official title
Roll-over to Corporation in Respect of Shares which are Identical Properties
Language
French
CRA tags
85(1)
Document number
Citation name
9030505
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633738
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-11-15 07:00:00",
"field_tags": []
}
Main text
24(1) 5-903050
  H. Woolley
  (613) 952-8108

19(1)

November 15, 1990

Dear Sirs:

Re:  Subsection 85(1) of the Income Tax Act ("the Act")

We are writing in response to your letter of October 30, 1990 in which you requested our opinion as to whether a taxpayer is entitled, pursuant to the provisions of subsection 85(1) of the Act, to select different elected amounts in respect of shares which are identical properties.

The Department's general position on this matter is set out in paragraph 7 of Information Circular IC 76-19R2, dated June 15, 1990 wherein it is stated that, "Pursuant to Section 85, each property is the subject of a separate election even though several properties may be listed on a single election form".

We trust these comments will be of assistance.

Yours truly,

for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and IntergovernmentalAffairs Branch