31 August 1990 Income Tax Severed Letter AC59739 - Tranfer of Property to Spousal Trust if Spouse not Resident of Canada

By services, 22 July, 2022
Official title
Tranfer of Property to Spousal Trust if Spouse not Resident of Canada
Language
English
Document number
Citation name
AC59739
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656970
Extra import data
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"field_proprietary_citation": [],
"field_release_date_new": "1990-08-31 08:00:00",
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Main text
24(1)                                        5-9739
                                             M.Shea-DesRosiers
                                             (613) 957-8953

Attention:19(1)

August 31, 1990

Dear Sir:

Re: Subsection 73(1) of the Income Tax Act (the "Act")

This is in reply to your letter of February 12, 1990 concerning the above-mentioned subject.

We agree with your interpretation that subsection 73(1) of the Act does not require the spouse to be a resident of Canada where the spousal trust which is resident in Canada is the transferee of the capital property in question.

We trust the above comments will be of assistance to you. We apologize for the delay in replying to your letter.

Yours truly,

for Director Financial Industries Division Rulings Directorate