| 19(1) | 1-881A |
| J.E. Harms | |
| (613) 957-2109 | |
| December 22, 1989 | |
| Dear Sirs: |
Re: 19(1) 24(1) Request for Advance Income Tax Ruling
24(1)
You have advised that, as a result of this concern, your client will be attempting to negotiate a restructuring of the proposed transactions.
As a favourable ruling regarding the application of subsection 55(2) of the Act is fundamental to the proposed transaction set our in your letters, we will do nothing further pending receipt of your advice as to any restructuring of the proposed transactions. In the meantime, we will forward a billing for the time spent on your request since the date of our last billing. We will be pleased to reopen your file upon receipt of written confirmation of your client's intention to proceed together with details of changes to the proposed transactions.
Yours truly,
for DirectorReorganizations and Non-Resident DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch