25 September 1989 Income Tax Severed Letter AC74361 - Amalgamation - Interpretation Bulletin IT-474R

By dwpv, 22 July, 2022
Official title
Amalgamation - Interpretation Bulletin IT-474R
Language
English
Document number
Citation name
AC74361
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656202
Extra import data
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Main text
Publication Division               Specialty Rulings Directorate
                                   A.A. Cameron
                                   957-2115
Mr. R. Shultis
Director

Interpretation Bulletin IT-474R 7-4361

We are forwarding a photocopy of our recent reply to a request for a technical interpretation concerning the ability of a corporation formed on an amalgamation (Amalco) to file an election pursuant to subsection 85(7) of the Act with regard to a prior transfer of assets involving a predecessor corporation. We are also enclosing a photocopy of a legal opinion received with regard to this matter.

In our view that opinion we have expressed is consistent with the position adopted concerning Amalco's ability to file a notice of objection or to appeal an assessment with regard to a predecessor corporation as stated in paragraph 35 of Interpretation Bulletin IT-474R .

Consideration should be given to adding a comment on this point in an amendment to Interpretation Bulletin IT-474R .

M.A. Hiltz for Director General Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch