19 October 1988 Income Tax Severed Letter 3-2099 - [Advance Income-Tax Ruling Request ]

By dwpv, 22 July, 2022
Official title
[Advance Income-Tax Ruling Request ]
Language
English
Document number
Citation name
3-2099
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656204
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1988-10-19 08:00:00",
"field_tags": []
}
Main text
XXXX
                                R. Albert
                               (613) 957-2098 
XXXX

OCT 19 1988

Dear Sirs:

Re: Advance Income-Tax Ruling Request XXXX

We are responding to your October 5, 1988 request for an advance income tax ruling on behalf of the above-noted taxpayer.

The issues on which you have requested advance income tax rulings (i.e. whether the international company will be held liable for taxes owing by XXXX or whether the international company has committee any acts which would make it liable to the penalties set out in subsection 163(2) or section 239 of the Income Tax Act) involve questions of fact. Accordingly, as set out in paragraph 14(1) of Information Circular 70-6R, such matters can not by their nature be the subject of an advance income tax ruling. In addition, we understand that these matters relate to issues which are currently under review by a district taxation office. For these reasons we regret that we are unable to consider your request for an advance income tax ruling.

Yours truly, ORIGINAL SIGNED BY ORIGINAL SIGNÉ PAR

B.W. DATH

Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch