913317
W.P. Guglich
(613) 957-2102
24(1)Attention: 19(1)December 17, 1991 Dear Sirs:
Re: Discretionary Dividends This is in reply to your letter of November 28, 1991 wherein you request clarification of the Department's position regarding the 1984 "Revenue Canada Round Table" question 82, alternative 2.
Our views as expressed in alternative 2 of question 82 at the 1984 "Revenue Canada Round Table" have not changed and would also be applicable where the inactive shareholder is a corporation which deals at arms length with the active shareholders.
We trust our comments will be of assistance to you.
Yours truly,
G. Thornley for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch
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