13 July 1990 Income Tax Severed Letter ACC9484 - Request for an Advance Income Tax Ruling

24(1)                      901364
                                               G. Thornley
                                               (613) 957-2101

Attention:          19(1)

JULY 13 1990

Dear Sirs:

This is in reply to your June 19, 1990 request for an Advance
Income Tax Ruling on behalf of                                    
           24(1)    
We also confirm our telephone conversation (Thornley    19(1) of
July 4, 1990 with           concerning this matter.

As discussed with          19(1)                   on July 4,
1990 advance income tax rulings given by the Department will have
application only to the taxpayer or taxpayers who requested it.
Rulings are rarely given on behalf of a group of unnamed persons
such as donors to charities. Rulings are also not given on
questions of fact unless it is possible to pre-determine all the
material facts and those facts can reasonably be expected to
prevail or be made to prevail. As your ruling request falls into
both of these areas we are unable to issue the advance income tax
ruling that you request. We are, however, prepared to offer the
following comments.

Our comments

                                 24(1)

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We trust our comments, which are as indicated, an expression of opinion only, will prove helpful.

Your deposit of $400.00 will be returned shortly.

Yours truly,

for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch