28 February 1991 Income Tax Severed Letter

By services, 22 July, 2022
Language
English
Document number
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656448
Extra import data
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"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1991 [MR91_194.197 - FE91_224.226]/FE91_285 — Application of GAAR to a Cross-border Purchase Butterfly Reorganization"
],
"field_proprietary_citation": [],
"field_release_date_new": "1991-02-28 07:00:00",
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}
Main text

Feb 28, 1991

Technical Publications Division    Rulings Directorate
                                   J.E. Harms
                                   957-2109
Attention:  J.A. MacFarlane
                                   7-910234

Publication of Advance Income Tax Ruling 1-957 (the "Ruling")

In your memorandum of January 23, 1991, you requested our views regarding the suitability of the Ruling for publication. The main issue in the Ruling involves the application of subsection 245(2) of the Income Tax Act to a cross-border purchase butterfly reorganization. While we may have original recommended that the Ruling be published, the main issue in the Ruling has since been dealt with in a number of other rulings that have been or are being prepared for publication. Therefore, in our view, publication of the Ruling is no longer necessary or advisable.

Director Reorganizations and Non-resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch

                                                           000285