XXXX D.Y. Dalphy (613) 957-2134
May 8, 1987
XXXX
This is in reply to your letter of March 11, 1987 wherein you requested a ruling concerning the deductibility of losses and your inability to enforce the judgment of the Ontario Supreme Court in respect or an action between yourself and XXXX
We must advise that an advance income tax ruling will not be issued in a situation such as this where the matter on which a determination is requested is primarily one of fact. Further, advance income tax rulings will not be issued in respect of completed transactions. We enclose for your reference a copy of Information Circular 70-6R (and the Special Release thereto) which sets out the guidelines under which rulings are issued.
Although we must decline to rule on the matter raised in your letter, we have forwarded this correspondence to Mr. A.J. Johnson, Chief of the Central Enquiries and Initial Assessing Section of the Toronto District Taxation Office (telephone: (416) 973-3301), for his consideration.
We enclose copies of Interpretation Bulletins IT-15982 and IT-442
for your reference and we advise that officials of the Toronto District Taxation Office will contact you in the near future.
We hope this information will assist you.
Yours truly,
ORIGINAL SIGNED BY ORIGINAL SIGNé PAR
P. D. FUOCO
for Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch
Enclosures 50(1) 20(1)(p)