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Wyman W. Webb (613)957-4364
September 30, 1987
Dear Sir,
We are writing in response to your letter of July 21, 1987 in which you requested our confirmation that the opinions expressed in a letter from Revenue Canada Taxation dated February 21, 1985 still reflect the opinion of Revenue Canada Taxation. To date no amendments to the Income Tax Act have been introduced that would affect the opinion as stated in the letter referred to above, a copy of which is enclosed, and therefore, the comments contained in that letter are still applicable. With respect to any rulings on the application of the sections referred to in that letter, we would consider each ruling request on the basis of the facts presented for that ruling and the general statement on rulings contained in the last paragraph of the letter of February 21, 1985 would no longer be applicable.
Please note that the above opinions are not advance rulings and therefore they are not binding on the Department. If advance rulings are required please note the procedure to be followed as set out in Information Circular No. 70-6R.
We trust that our comments will be of assistance.
for Director Bilingual Services and Resource Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch