31 August 1990 Internal T.I. 59739 F - Transfer of Property to Spousal Trust if Spouse not Resident of Canada

By services, 18 January, 2022
Official title
Transfer of Property to Spousal Trust if Spouse not Resident of Canada
Language
French
CRA tags
73(1)
Document number
Citation name
59739
Severed letter type
Technical Interpretation - Internal
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633881
Extra import data
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"field_release_date_new": "1990-08-31 08:00:00",
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Main text
24(1) 5-9739
  Maureen Shea-DesRosierss
  (613) 957-8953

Attention: 19(1)

August 31, 1990

Dear Sir:

Re: Subsection 73(1) of the  Income Tax Act (the "Act")

This is in reply to your letter of February 12, 1990 concerning the above-mentioned subject.

We agree with your interpretation that subsection 73(1) of the Act does not require the spouse to be a resident of Canada where the spousal trust which is resident in Canada is the transferee of the capital property in question.

We trust the above comments will be of assistance to you. We apologize for the delay in replying to your letter.

Yours truly,

for Director Financial Industries Division Rulings Directorate