Revenue Canada Taxation
D. Holtz (613) 993-6201
November 20, 1985
Dear Sirs:
Re: Subsection 85(1) and Subparagraph 256(7)(a)(i) of the Income Tax Act ----------------------------------------------
This is in reply to your letter of October 8, 1985 wherein you requested certain technical interpretations with respect to the above-referenced provisions of the Act.
As your letter deals with a fact situation and proposed transactions, your request should be the subject of an advance income tax ruling. We are not prepared to offer any comments without a full disclosure of all relevant facts and transactions.
Yours truly,
Chief Corporate Reorganizations Section Reorganization and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch