18 April 1991 Income Tax Severed Letter

April 18, 1991

HEAD OFFICE                             HEAD OFFICE
Audit Programs Directorate              Rulings Directorate
Special Audits Division                 Resource Industries
E.H. Gauthier                             Section
Director                                Peter Lee
                                        957-9769

Attention:  B.A. Chisholm               7-910656

Industry Issue Report #09 Amending Joint Exploration Corporation Renunciations

We are writing in reply to your memorandum of March 6, 1991, in which you requested our confirmation that the positions relied upon by you which are reflected in report #09 are the current policies of Rulings with respect to amending joint exploration corporation renunciations.

We confirm that our general positions with respect to amending joint exploration corporation renunciations, as stated in our memorandum of December 8, 1988 (7-3144), continue to be our current positions on the matter. However, we would ask that you consider modifying the report by clarifying the first sentence under the heading of "Department's Policy". Our suggested wording of the sentence is:

The Department is prepared to adjust the elected and renounced amounts in the resource pools of a shareholder corporation for the particular taxation year with respect to which a JEC renunciation was made, in order to reflect the reclassification of the expenses resulting from an audit of the JEC.

Director Bilingual Services and Resource Industries Division Rulings Directorate

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