4 August 1989 Income Tax Severed Letter ACC8392 - Loan to Non-resident

By services, 22 July, 2022
Official title
Loan to Non-resident
Language
English
Document number
Citation name
ACC8392
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656522
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1989-08-04 08:00:00",
"field_tags": []
}
Main text

August 4, 1989

FROM - HEAD OFFICE Specialty Rulings Directorate D.Y. Dalphy (613) 957-2117

TO - PENTICTON DISTRICT OFFICE

Attention: Mr. B. Sixsmith
           Chief of Audit

SUBJECT: 24(1)

This is in reply to a memorandum of P.J. Kelly, Chief of Audit, dated April 8, 1988.

We agree with the taxpayer's argument that section 17 of the Income Tax Act is not applicable in respect of the interest-free advances to the subsidiaries because they are resident in Canada. The issue of interest deductibility was considered by the Policy Committee.

On the basis of the legal and technical advice received, it has been determined that the reassessment of the 24(1) should proceed.

D.Y. Dalphy A/Chief Foreign Section Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch