19(1) 910637
C. Tremblay
613) 952-1361April 4, 1991
19(1)Re: Incorporation of Legal Practices
This is in reply to your letter of March 6, 1991, and further to a telephone conversation of April 3, 1991 (19(1) Tremblay), wherein we discussed the department's position in respect of a request for a ruling where the legislation has not yet been passed. We confirm that, since Ontario Legislature Bill 45 has not been proclaimed into law, we cannot issue a ruling that is based on a proposed transaction awaiting it's enactment. However, if you have general concerns and wish our views regarding transfers of assets from a partnership or a proprietorship to a corporation using section 85 of the Income Tax Act, we suggest you write to us for our comments.
Yours truly,
for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch
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