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R.P. Laramy (613)957-2746
June 23, 1988
Dear Sirs:
Re: Interpretation Bulletin 239R2 ("239R2")
This is in reply to your letter of March 31, 1988 concerning the Department's policy in respect of losses arising from loan guarantees.
The tax consequences of the situation you described involve a question of fact which can only be determined upon a review of all material facts and documentation. Such a review is the responsibility of the District Taxation Office serving your client's area. We would suggest you contact the appropriate office for advice on this matter.
Yours truly,
for Director Financial Industries Division Rulings Directorate