14 December 1990 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
657561
Extra import data
{
"field_external_guid": [
"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1990 [DC90_029.031 - NV90_431.432]/DC90_176 — Transfer of Property to Corporation by Shareholders"
],
"field_proprietary_citation": [],
"field_release_date_new": "1990-12-14 07:00:00",
"field_tags": []
}
Main text
24(1)
                                        903296
                                        M.P. Sarazin
                                        (613) 957-2125
          19(1)

Dear Sirs:

Re: Subsection 85(1) of the Income Tax Act (Canada) (the "Act")

We are writing in response to your letter of November 19, 1990 wherein the situation described is identical to the one described in your letter of October 30, 1990 except for the additional statement that one share qualifies as a qualified small business corporation share, as that term is defined in subsection 110.6(1) of the Act, and the other does not qualify.

Notwithstanding this minor change to the situation described, our general position regarding this situation continues to be as reflected in our November 15, 1990 response to your original letter.

Yours truly,

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