1999 Ruling 9918323 - XXXXXXXXXX Business of a Commercial Trust -- summary under Paragraph 206(1)(h)

Mutual fund units would not be considered to be foreign property given that more than 80% of the fund's property (in terms of cost amount) was invested in interest-bearing promissory notes of a "subsidiary" unit trust ("CT") with a 25-year term, with the balance of its assets as units of CT.