13 November 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
658089
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]/NV90_246 — Intercorporate Dividends"
],
"field_proprietary_citation": [],
"field_release_date_new": "1990-11-13 07:00:00",
"field_tags": []
}
Main text
24(1)
                                        901891
                                        J. Teixeira
                                        (613) 957-2119
          19(1)

Dear Sirs:

We are writing in reply to your letter of September 27, 1990, wherein you have expressed your opinion in regard to the particular situation which was described in our letter to you dated September 7, 1990.

Our opinion remains as stated in our letter of September 7, 1990. In your proposed transactions the provisions of paragraph 55(3)(a) of the Income Tax Act (the "Act") will not exempt the dividends received by Newcos 1 and 2 from the application of subsection 55(2) of the Act. Consequently, the requirements of paragraph 55(3)(b) of the Act will have to be satisfied.

Yours truly,

for Director Reorganizations and Non-Resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch