16 October 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
657703
Extra import data
{
"field_external_guid": [
"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1990 [NV90_433 - OC90_200.201]/OC90_180 — Subsidiary's Expenditure Year where Transfer of Acounts to Parent on Winding-up"
],
"field_proprietary_citation": [],
"field_release_date_new": "1990-10-16 08:00:00",
"field_tags": []
}
Main text
Current Amendments and                       Rulings Directorate
 Regulations Division                        L.A. McCarron-McGuire
                                             957-2092
Attention: B. Bryson                         902293

SUBJECT: Paragraph 88(1.3)(a) of the Income Tax Act (the "Act")

We are enclosing a copy of a recent response to an inquiry concerning the above-noted provision of the Act.

In our view, the omission in paragraph 88(1.3)(a) of a reference to the "expenditure year" of the subsidiary does not allow for the proper operation of paragraph 88(1)(e.3) in situations where the parent corporation was not in existence at the end of the subsidiary's "expenditure year", as that term is defined in subparagraph 88(1)(e.3)(i).

Yours truly,

M.A. Hiltz for Director General Reorganizations and Non-resident Division Rulings Directorate Legislations and Intergovernmental Affairs Branch