28 November 1989 Income Tax Severed Letter AC58728 - Tax on Corporate Distributions

By services, 22 July, 2022
Official title
Tax on Corporate Distributions
Language
English
Document number
Citation name
AC58728
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657252
Extra import data
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"field_release_date_new": "1989-11-28 07:00:00",
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Main text

Nov 28 1989

Dear Sirs:

Re:

We are writing in response to your letter of September 26, 1989 which outlined a matter relating to our letter to you (the "Opinion Letter") of November 25, 1987.

The Opinion Letter concerned the application of the provisions of section 183.1 of the Income Tax Act (the "Act"), as they read at that time with regard to 

                            24(1)

You have indicated that in your view

                       24(1)
The provisions of section 183.1 of the Act were amended
applicable with respect to transactions entered into on or after
September 13, 1988, other than transactions that were part of a
series of transactions, determined without reference to
subsection 248(10) of the Act, commencing before September 13,
1988 and completed before 1989.
                              24(1)

In our opinion

The above comments constitute an expression of opinion only and are not binding on the Department as detailed in Information Circular 70-6R dated December 18, 1978.

Yours truly, for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch