19(1)
November 6, 1989
Revenue Canada 88 Metcalfe Street Ottawa, Ontario K1A 0L8
Attention: Rulings - Leasing & Financing Division
Dear Sirs:
Re: Paragraphs 12(1)(x)(viii), 13(7.4), 53(2)(s) and 53(2.1) of the Income Tax Act
19(1)
I have noticed that there is no technical provision for a partnership to make the election outlined in subsection 13(7.4) of the Income Tax Act. I understand that it is your assessing policy that a partnership may use the election procedure set out in paragraph 96(3) of the Act in order to make the election as a "taxpayer" pursuant to subsection 13(7.4) in circumstances that otherwise comply with the above captioned provisions. I also understand that Kevin Donnelly, of your offices, has previously dealt with this matter in a letter on file under subsection 13(7.4).
Would you please provide me with written confirmation of Revenue Canada's position with respect to an election by a partnership pursuant to subsection 13(7.4). Thank you for your attention to this matter.
Yours truly,
19(1)19(1)