D.Y. Dalphy (613) 957-2122 Dec 14 1987
Dear Sirs:
Re: Saskatchewan Livestock Investment Tax Credits
This is in reply to your letter of July 29, 1987 regarding tax credits provided pursuant to The Livestock Investment Tax Credit Act, 1985 and subsection 53(2.1) of the Income Tax Act (the "Act").
In our view, the transfer by a corporation of livestock investment tax credits to its shareholders may trigger double taxation - the corporation could be taxable on these amounts under section 9 and subsection 56(2) or 56(4) of the Act and the shareholder under subsection 15(1) or paragraph 12(1)(x) of the Act. Accordingly, your enquiry and our related views have been provided to Enquiries and Taxpayer Assistance Division, Assessing Directorate, which will arrange to provide a direct response to your enquiry.
Yours truly,
XXXXXXXX
for Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch