| 19(1) | File No. 5-8878 |
| C. Robb | |
| (613) 957-2744 |
November 3, 1989
19(1)
Re: Subsection 132(6) and Securities Lending
We are writing in response to your letter of October 6, 1989, wherein you requested our opinion as to whether securities lending by a trust constitutes the investment of funds for the purposes of subsection 132(6) of the Income Tax Act (Canada).
It is our opinion that, in general, the lending of securities would constitute an undertaking that is the investing of funds of the trust within the meaning of subsection 132(6).
This opinion is of a purely general nature. In accordance with paragraph 24 of Information Circular IC 70-6R, it does not constitute an advance income tax ruling and consequently is not binding on the Department.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate