March 28, 1991
W. M. Lynn Head Office Section Chief Rulings Directorate Appeals and Referrals Division L.A. McCarron-McGuire Appeals Branch (613) 957-2092 Head Office
Attention: M.S. Lalonde
8-910339
24(1)Application of subsection 18(4)We are writing in response to your memorandum, dated February 4, 1991, in which you requested our views on whether the Notices of Objection filed by 24(1) (the "taxpayer") for 1986, 1987 and 1988 should be allowed.
It is our view that the words in subsection 18(4) and subparagraph 18(5)(a)(ii) are clear and unambiguous.
24(1)
Further, we agree with the position expressed by Business Files Audit and supported by the International Audits Section of the Hamilton District Office that Article XXII of the Canada - U.K. Income Tax Convention (1978) does not provide relief to the taxpayer in these circumstances.
As indicated in a letter, dated November 9, 1990, from the Department of Finance ("Finance") to the taxpayer's representative (a copy of which letter you forwarded to us on March 14, 1991),
24(1) 21(1)(b)
Director Reorganizations and Non-resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch
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