A. Seidel (613) 957-8960
24(1)
Attention: 19(1)
July 27, 1990
Dear Sir:
This is in reply to your letter dated April 17, 1990 with respect to the application of subsection 153(4) of the Income Tax Act (the "Act") where a shareholder is identified in the corporation's share register but cannot be located.
Provided that the corporation is certain that the name of the shareholder in the share register is the beneficial owner of the shares, it is our view that for the purposes of subsection 153(4) of the Act the shareholder beneficially entitled to receive an amount from the corporation is not "unknown".
While we hope our comments are of assistance to you they do not constitute an advance income tax ruling and therefore are not binding on the Department in respect of a specific situation.
Yours truly,
F. Lee Workman for Director Financial Industries Division Rulings Directorate