2 January 1990 Income Tax Severed Letter ACF3343 - Attribution Rules

By services, 22 July, 2022
Official title
Attribution Rules
Language
English
Document number
Citation name
ACF3343
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656916
Extra import data
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"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-01-02 07:00:00",
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Main text

January 2, 1990

Mr. L. Farber                                     R. D. Weil
Director                                          (957-2066)
Tax Policy and Legislation Branch
Department of Finance
140 O'Connor Street                               BY HAND
L'Esplanade Laurier
17th Floor, East Tower
Ottawa, Ontario K1A 0H5

Dear Len:

          Attribution Rules
          Subsection 74.5(7) of the Act
          This is in reply to your letter of October 16, 1989 and
further to our letter of October 31, 1989 to you on the same
subject.
          Where subsection 74.5(7) is applicable, the property
loaned by the third party is deemed to have been loaned to the
debtor by the guarantor for the purposes of, inter alia,
subsection 74.4.
          In order for section 74.4 to apply, one of the main
purposes of the deemed loan must have been to reduce the income
of the guarantor and to benefit the debtor.

21(1)(b)

Yours sincerely,

B.J. Bryson Acting Director Current Amendments and Regulations Division RDW/