C. Thériault (613) 957-8981
XXXX
November 28, 1988
Dear Sirs,
This is in reply to your letter dated October 12, 1988 wherein you asked for our position as to whether or not subsection 98(6) of the Income Tax Act (the "Act") is intended to apply to facilitate the voluntary merger of existing operating partnerships.
The Department's position continues to be that the provisions of subsection 98(6) of the Act do not apply to facilitate the merger of partnerships but they apply to deem a partnership to be the continuation of a predecessor partnership.
We trust the above comments will be of assistance to you.
Yours truly
for Director Bilingual Services and Resource Industries Division Rulings Directorate