25 January 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
656697
Extra import data
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"field_external_guid": [
"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1991 [FE91_227 - JA91_325.335]/JA91_053 — Mutual Fund Trust"
],
"field_proprietary_citation": [],
"field_release_date_new": "1991-01-25 07:00:00",
"field_tags": []
}
Main text
24(1)                         5-903662
                                        D.S. Delorey
                                        (613) 957-3494
          19(1)

January 25, 1991

Dear Sirs:

This is in reply to your letter of December 3, 1990 concerning mutual fund trusts.

It is our view that there is nothing in subsection 132(6) of the Income Tax Act precluding a mutual fund trust from borrowing money to acquire mortgages and other similar investments, or to acquire real property as an investment on the security of mortgage. We caution, however, that the activities with respect to real estate must be limited to investment. For example, participation in decisions concerning real estate development would be an undertaking additional to that of investment of funds.

The above comments are an expression of opinion only and are not binding on the Department, as explained in paragraph 21 of Information Circular 70-6R2. We trust, however, that they are of assistance to you.

Yours truly,

for Director Financial Industries Division Rulings Directorate

000053