| August 30, 1989 | |
| To: Calgary District Office | From: Head Office |
| G. Lawrence | Resource Industries Section |
| Chief of Tax Avoidance | Frank S. Gillman |
| (613) 957-9768 | |
| Attention: R. Jahraus | |
| Room 350 | File No. 7-4230 |
Subject: 24(1)
Following your memorandum of August 16, 1989 and the telephone conversation (Gillman/Jahraus) of August 29, 1989, we are enclosing for your review advance income tax ruling issued to 24(1) dated September 28, 1984 under our file number 3-4569. We have also included certain amendments we granted to the said ruling after it was issued.
As was explained to you during the above-mentioned telephone conversation, we have not been able to locate any tax rulings regarding the disposition of the Net Profits Interest by 24(1).
As you will notice on review of the enclosed documents, the ruling we are sending you was issued on September 28, 1984, a date after April 1984. Therefore, if the disposition occurred in April of 1984, the ruling we are providing you can not apply since a ruling can only apply and be issued in respect of a definite transaction or transactions which the taxpayer is contemplating,and not on completed ones or those which have already commenced. Should you require further clarification on this point, please refer to Information Circular 70-6R dated December 18, 1978, or contact Frank Gillman at (613) 957-9768 on this issue or any other further information or technical assistance you may require.
ChiefResource Industries SectionBilingual Services and Resource Industries DivisionRulings Directorate