19 June 1990 Income Tax Severed Letter ACC9413 - Amalgamation

By services, 22 July, 2022
Official title
Amalgamation
Language
English
Document number
Citation name
ACC9413
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
658131
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-06-19 08:00:00",
"field_tags": []
}
Main text
24(1)                                     901275
                                          W.C. Harding
                                          (613) 957-8953

Attention: 19(1)

July 19, 1990

Dear Sirs:

This is in reply to your letter of June 13, 1990, requesting our position concerning the application of subsection 105(1) of the Income Tax Act in view of the outcome of S. Cooper v. MNR (1989) 1 CTC 66.

It is our position that the decision reached in the Cooper case will be of consideration in our assessment of taxpayers under the provisions of subsection 105(1) of the Act in similar or identical situations. It however remains our position that each case must be determined on an individual case by case basis.

We trust that this information is satisfactory to your needs.

Yours truly,

for Director Financial Industries Division Rulings Directorate