| 92-2121 | |
| 922155 | |
| 24(1) | Michael Cooke |
| (613) 957-8972 |
Attention: 19(1)
July 22, 1992
Dear Sirs:
Re: Prescribed Debt Obligation-Regulation 7000(1)(c)
This is in reply to your letter of July 15, 1992 concerning your request for a technical interpretation regarding the above noted Regulation.
Your specific concern is whether a debt obligation which has a floating interest rate for the first three months, in and of itself, will cause the obligation to be a prescribed debt obligation pursuant to paragraph 7000(1)(c) of the regulations to the Income Tax Act.
The application of 7000(1)(c) will depend on all the factors pertinent to any given situation and therefore we cannot give a general response to your question.
Yours truly,
Section ChiefLeasing and FinancingFinancial Industries DivisionRulings Directorate