D. Yuen (613) 957-2111
19(1)
March 30, 1990
Dear Sirs:
Re: Acquisition of Control of Parent Company
We are writing in reply to your letter of January 19, 1990 wherein you requested our views on whether an acquisition of control of a parent company will cause a subsidiary company to also have a deemed year end under subsection 249(4) of the Income Tax Act (Canada) (the "Act").
It is the Department's position that control refers to direct and indirect control. Thus the acquisition of control of a parent company also results in the acquisition of control of any subsidiary companies. The subsidiary company will, therefore, have a deemed year end pursuant to subsection 249(4) of the Act.
The comments expressed are not advance income tax rulings and are not considered binding on the Department, in respect of any taxpayer, in accordance with paragraph 24 of Information Circular 70-6R dated December 18, 1978.
Yours truly,
ILLEGIBLE SIGNATURE for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch