| 24(1) | R. Albert |
| (613) 957-2098 | |
| EACC9284 | |
| Attention: 19(1) |
August 22, 1990
Dear Sirs:
Re: Use of Provisos in Advance Income Tax Rulings
We are writing in reply to your verbal request for a statement of the general usage of the phrase "provided that the partnership is a partnership at law" as a proviso in advance income tax rulings issued by the Department.
In this respect, we confirm that the above-noted phrase has been customarily used by this Division in recent years as a general proviso in respect of advance income tax rulings issued where the proposed transactions include the formation of a partnership.
We trust that this information will be of assistance to you.
Yours truly,
B.W. DathDirectorBusiness and General DivisionRulings DirectorateLegislative and IntergovernmentalAffairs Branch