5-911992
R. Albert
24(1) (613) 957-2135
19(1)November 20, 1991
Dear Sirs:
Re: Opinions on Scientific Research Tax Credit ("SRTC") "Quick Flip" Investments
We are writing in reply to your letter of July 18, 1991 wherein you requested written confirmation that on or about November 23, 1984, Revenue Canada ceased issuing advance income tax rulings or opinions on whether a "quick-flip" SRTC transaction amounted to an agreement in writing entered into on or before October 10, 1984.
We can confirm that advance income tax rulings were not issued regarding whether financing arrangements would satisfy the transitional provisions contained in the Department of Finance Release No. 84-151 dated October 10, 1984. We can also confirm that opinions with respect to whether financing arrangements would satisfy the aforementioned transitional provisions in that they constituted "agreements in writing entered into on or before October 10, 1984 or arrangements evidenced in writing and substantially advanced" before October 10, 1984 within the meaning of the Department of Finance Release No. 84-151 dated October 10, 1984, generally ceased to be issued on or about November 23, 1984. We can also confirm that no opinions were provided by Revenue Canada with respect to the grandfathering of SRTC issues either at October 10, 1984 or at May 23, 1985 subsequent to November 20, 1985.
We trust that these comments will be of assistance.
Yours truly,
G. Thornley for Director Business and General Divisions Rulings Directorate Legislative and Intergovernmental Affairs Branch
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