18 February 1991 Income Tax Severed Letter

By services, 22 July, 2022
Language
English
Document number
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657446
Extra import data
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"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1991 [MR91_194.197 - FE91_224.226]/FE91_135 — Convertible Property Rules and Stock Exchange Approved Coat Tail Provisions"
],
"field_proprietary_citation": [],
"field_release_date_new": "1991-02-18 07:00:00",
"field_tags": []
}
Main text
24(1)                         5-9589
                                             S.J. Tevlin
                                             (613) 957-2118
               19(1)

Feb 18, 1991

Dear Sirs:

Re: Technical Interpretation Request Respecting the Application of Section 51 of the Income Tax Act (the "Act") to Stock Exchange Approved Coat Tail Provisions

We are writing in response to your letters of February 8 and December 18, 1990 wherein you requested that we reconsider our position regarding coat tail provisions, as described in our letter dated May 17, 1988.

We apologize for the delay, however, we conducted a thorough review of our previously stated position and an extensive analysis of your submissions. Regretfully, we must advise you that our interpretation remains the same as that described in our previous letter.

Yours truly,

Director Reorganizations and Non-Resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch

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