| 19(1) | File No. 5-8179 |
| Peter Lee | |
| (613) 957-2745 |
June 28, 1989
Dear Sir:
Re: Section 77 - Bond Conversion
We are writing in reply to your letter of June 5, 1989, wherein you requested our opinion with respect to the interpretation of the word "bond" for purposes of section 77 of the Act.
Without a review of all the relevant facts we are reluctant to provide a definitive answer. However it would seem that a debenture could be subject to the provisions of section 77 of the Act.
Our opinion is not an advance income tax ruling and accordingly is not binding on the Department. We hope that our opinion is helpful to you.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate