7 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
658143
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_287 — Acquisition of Obligation by Trust"
],
"field_proprietary_citation": [],
"field_release_date_new": "1990-11-07 07:00:00",
"field_tags": []
}
Main text
24(1)
                                        5-902511
                                        D.S. Delorey
                                        (613) 957-3494
          19(1)

November 7, 1990

Dear Sirs:

This is in reply to your Facsimile of September 19, 1990 concerning subparagraph 4900(1)(i)(iii) of the Income Tax Regulations (the "Regulations").

It is our view that the words "at the time the obligation is acquired" in subparagraph 4900(1)(i)(iii) of the Regulations refers to the day in which the plan trust acquires the obligation and not to a particular hour in that day. Thus, where the plan trust has acquired the obligation of the corporation an a particular day and at some time during that day the corporation meets the requirements set out in subparagraph 4900(1)(i)(iii) of the Regulations, the obligation could represent a qualified investment for the plan trust.

The above comments are an expression of opinion only and are not binding on the Department, as explained in paragraph 21 of Information Circular 70-6R2. We trust however that they are of assistance to you.

Yours truly,

for Director Financial Industries Division Rulings Directorate