Current Amendments and Rulings Directorate
Regulations Division L.A. McCarron-McGuire
957-2092Attention:R. D'Aurelio 902860
SUBJECT: Subsection 85(1.1) of the Income Tax Act (the "Act")
We are enclosing a copy of a recently issued technical interpretation (901734) which outlines our views on whether an option to acquire real property qualifies as "eligible property" within the meaning of paragraph 85(1.1)(f).
We wish to advise you of the position taken, since it is not clear whether our interpretation of subsection 85(1.1), as outlined in paragraph three of the letter to the taxpayer, will produce appropriate results.
Yours truly,
R.J.L. Read Director General Rulings Directorate Legislative and Intergovernmental Affairs Branch