| 19(1) | File No. 5-7279 |
| J.D. Jones | |
| (613) 957-2104 |
June 6, 1989
Dear Sirs:
Re: Paragraph 67.1(2)(e) of the Income Tax Act (the "Act")
This is in reply to your letter of December 20, 1988, regarding the above-noted subject addressed to Mr. Don Joy, which has been referred to this Division for reply. We apologize for the delay in replying.
The types of situations to which the exclusion in paragraph 67.1(2)(e) of the Act was intended to apply are mentioned in the June, 1988 "Explanatory Notes to Legislation Relating to Income Tax" issued by the Ministry of Finance. The Department's general position on the subject is now set out in Interpretation Bulletin IT-518 dated March 28, 1989.
At this time we are unable to provide you with a definitive reply with respect to the specific situations raised in your letter. We will review the matter further and make the Department of Finance aware of the points you have raised.
We regret that we are unable to be of greater assistance at this time
Yours truly,
for DirectorSmall Business and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch