Robin Jackson Canadian Film Certification Office Arts and Culture Branch Department of Communications Ottawa, Ontario KIA 0M5
B. Toyota 995-1787
January 14, 1981
Dear XXXX
This is in reply to your memorandum of January 6, 1981 concerning income tax problems encountered by investors in the videotape productions entitled XXXX
We have reviewed the letter from XXXX and are not sure what the specific problems are. In any case, since the problems have arisen as a result of an audit by one of our district offices, we would not be in a position to comment on the problems except through our district office. Accordingly, all representations should be made to the district office concerned.
Notwithstanding the above, we draw your attention to subsection 1103(2c) of the Income Tax Regulations which might have had application to the situation, if elections had been made during the years concerned. Whether or not the district office would accept late-filed elections is, of course, at their discretion.
We regret that we could not be mere helpful at this time.
Yours truly,
for Director Corporate Rulings Division Corporate Rulings Directorate Legislation Branch
BT/jw