2007 Ruling 2007-0237351R3 - Stock-link Notes -- summary under Paragraph 7000(2)(d)

Ruling respecting a stock-linked note where no return (other than in extraordinary circumstances) was payable until maturity, that so long as any variable return early payment amount does not become payable before the year in which the final valuation date occurs, no amount will be required to be included under s. 12(4) in the income of an individual note holder, and that the variable return will be required to be included under s. 12(1)(c) on maturity.