Revenue Canada Revenu Canada Taxation Impôt
Head Office Bureau principal
Your file Votre reference Our file Notre reference S. Leung (613) 957-2116
FEB FEV - 2 1989
Dear Sirs:
Re: Section 88 of the Income Tax Act (Canada) (the "Act") and Interpretation Bulletin IT-126R ---------------------------------------------------
This is in reply to your letter of January 13, 1989 wherein you requested our opinion on when a corporation is considered to be wound up for purposes of section 88 of the Act in the hypothetical situation described in your letter.
The situation outlined in your letter appears to involve an actual situation which you should refer to the appropriate District Taxation Office. However, generally we agree with your view that a corporation is considered to have been wound up although consents to the dissolution have not been received and articles of dissolution have not been filed with the appropriate authority.
The foregoing comment is not a ruling and in accordance with the guidelines explained in Information Circular 70-6R dated December 18, 1978, is not binding on the Department.
Yours truly,
for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch