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S. Leung (613) 957-2116
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MAR 20 1989
Dear Sirs:
Re: Paragraph 256(1.1)(d) of the Income Tax Act (Canada) (the "Act")
This is in reply to your letter of November 28, 1988 with respect to the prescribed rate of interest for the purposes of the above-noted paragraph of the Act.
We agree with your views that for the period after 1983 the prescribed rate of interest is the rate specified in Section 4301 of the Income Tax Regulations. We also agree that for the period prior to January 1, 1984, the Act and the Income Tax Regulations do not contain a prescribed rate of interest for purposes of paragraph 256(1.1)(d) of the Act. We have referred this matter to our Current Amendments and Regulations Division and have been advised that the Department of Finance is now reviewing the matter.
Yours truly,
for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch