15 February 1990 Ruling HBW4125U31A F - Canada-US Income Tax Convention - Interest Income Exemption

We are writing in follow-up to our letter of August 16, 1989, concerning the tax status in Canada of the 24(1).  We apologize for the delay in replying.

Pursuant to Article XI, subparagraph 3(a) of the Canada-United States Income Tax Convention, interest income arising in Canada and paid to the corporation is exempt from tax in Canada.  You may provide photostatic copies of this letter to paying or disbursing agents as their authority to make payments of interest to the 24(1) without withholding Canadian non-resident income tax.  In the event of a change in status of the Corporation or an amendment or repeal to Article XI of the Convention (i.e. Protocol or new treaty), the above authorization is revoked.

We trust you will find this to your satisfaction.

Yours sincerely,

C. SavageA/DirectorProvincial and International Relations Division

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