19(1) 5-9319
R.B. Day
(613) 957-2136
JAN 11 199019(1) 24(1)
We are writing in reply to you letter of December 19, 1989, wherein you requested our approval of the proposed restructuring of the Company.
We reviewed your submission, with specific reference to the corporate structure set out in Exhibit 2 of your submission. This restructuring would appear to be acceptable within the guidelines discussed during our meeting of December 7, 1989.
However, since the corporate restructuring relates to a factual situation and proposed transactions that can only be considered within the ambit of an advance income tax ruling request, you may wish to re-submit your request for approval in a formal request for an advance income tax ruling.
Yours truly,
B.W. Dath Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch