This Ruling has been obsoleted by AN 94(2)

Ruling 89-44

Capital Gains, Dividends and Interest Tax

The capital gain recognized by the partnership on January 10, 1989 does qualify for the sixty percent capital gains exclusion. Under the new tax act, capital gains which are earned, received in fact or constructively, accrued or credited to the taxpayer on or before February 8, 1989 are eligible for such exclusion.

LEGAL DIVISION

August 15, 1989