2005 Ruling 2005-0139661R3 - Withholding Index-Linked Notes -- summary under Clause 212(1)(b)(iii)(D)

A foreign-denominated index-linked note issued by a Canadian bank which did not provide for the return of the principal amount or any interest or other amount on the note prior to the maturity date, and with the return on the note being deducted by the bank for financial statement and tax purposes on the maturity date, would be exempt from withholding tax by virtue of s. 212(1)(b)(iii)(D).