24(1) 3-902636
W.C. Harding
(613) 957-895319(1)
January 15, 1991
Dear Sir:
Re: 24(1) Advance Income Tax Ruling
This is further to your letter of August 15, 1989 in request of the above noted ruling and our subsequent discussions thereon.
As you are aware, Revenue Canada recently revised its position concerning the redemption of mutual fund units which are governed by, and comply with, the regulations of the Ontario Securities Commission (the "OSC") and we are prepared to provide rulings in this respect. However, as discussed on October 2, 1990 (Harding 19(1) it was noted that your proposed fund does not appear to comply with subsection 11.05(1) of OSC Policy No. 39 and may not, in all cases, comply with section 13.02 of that same policy statement. At the time of that discussion, you advised that you would review your files and respond to these concerns. To date we have not received any submissions.
This request is now more than a year old and while we recognize that much of the delay in its finalization has been caused by the unavoidable time required to review our position, we would now greatly appreciate your assistance in resolving the case as soon as possible. If you have, instead, decided not to pursue your request, it would also be appreciated if you could so advise us.
We thank you for your cooperation in this matter.
Yours truly,
for Director Financial Industries Division Rulings Directorate
000016