2006 Ruling 2006-0208001R3 - Post-amble to paragraph 212(1)(b) -- summary under Participating debt interest

Where holders of notes receive at maturity a return linked to the performance of three mutual funds, the post-amble under s. 212(1)(b) will not apply so as to deny the availability of exemption in s. 212(1)(b)(vii). The issuer was not related to the mutual funds nor were the profits of the mutual funds linked to the issuer.