| 24(1) | 5-900870 |
| C. Robb | |
| (613) 957-2744 | |
| 19(1) | EACC9720 |
September 17, 1990
Dear Sirs:
Re: Definition of "Qualified Security" Proposed Subsection 260(1) of the Income Tax Act (the "Act")
We are writing in response to your letter of May 17, 1990 in which you requested our views on whether or not securities issued by the European Economic Community (the "EEC") and the International Bank for Reconstruction and Development (the "World Bank") are described in paragraph (c) of the definition of "qualified security" contained in proposed subsection 260(1) of the Act.
We regret that we are unable to provide you with any comments on the issue raised in your letter as we have to adopted any position concerning whether for purposes of proposed subsection 260(8):
a) the EEC can be considered a state or government; or
b) debts of the World Bank can be said to be guaranteed by a country.
These questions could be considered in response to a request involving a particular series of proposed transactions, submitted with the level of disclosure required for an advance income tax ruling, as explained in Information Circular 70-6R.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate