2000 Ruling 2000-0029483 - Interest paid to non-residents -- summary under Subparagraph 212(1)(b)(vii)

The controlling shareholder of the corporate borrower was a mutual fund trust which received most relevant services pursuant to management and services agreements with a company from whom the trust initially had purchased its assets. Termination of those agreements would be an acceptable event of default. Also the failure of the borrower to make an offer to repurchase the issued notes in the event of its failure to reinvest asset sale proceeds within a specified time was an acceptable event of default.