24(1) 901485
J. Teixeira
(613) 957-2119Attention: 19(1)
JUL 24 1990
Dear Sirs:
We are writing in response to your letter of July 4, 1990 in which you requested technical interpretations in respect to transactions between a number of unidentified shareholders and a corporation.
The facts described by you appear to relate to specific proposed transactions. Confirmation of the tax consequences of these transactions will only be provided in a response for an advance income tax ruling requested in accordance with the guidelines contained in Information Circular 70-6R dated December 18, 1978. Therefore, we are unable to comment on the transactions outlined in your letter.
Yours truly,
for Director Reorganizations and Non-Resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch