11 January 1991 External T.I. 9031935 F - Compound Interest CSBs on Death of a Bond Holder

By services, 18 January, 2022
Official title
Compound Interest CSBs on Death of a Bond Holder
Language
French
CRA tags
70(2), 70(3)
Document number
Citation name
9031935
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
630368
Extra import data
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"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1991-01-11 07:00:00",
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Main text

5-903193

Dear Sirs:

This is in reply to your letter of October 31, 1990 wherein you requested our opinion on the application of subsection 70(2) of the Income Tax Act (the "Act") as it applies to compound interest Canada Savings Bonds (CSBs) on the death of a bond holder.

It is our view that interest accrued on a CSB  to the November 1 date preceding the date of death represents a "right or thing" for purposes of subsections 70(2) and (3) of the Act.  Interest accruing from November 1 to the date of death is considered to be an amount referred to in paragraph 70(1)(a) of the Act and therefore not eligible for inclusion under subsection 70(2) of the Act.

We trust the above comments will be of assistance to you.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate