3 January 1990 Internal T.I. F3419 F - Interest Rate Protection Agreement ("IRPA")

By services, 18 January, 2022
Official title
Interest Rate Protection Agreement ("IRPA")
Language
French
CRA tags
20(1)(m)(ii)
Document number
Citation name
F3419
Severed letter type
Technical Interpretation - Internal
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633409
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-01-03 07:00:00",
"field_tags": []
}
Main text
  January 3, 1990
Director General Current Amendments and
Rulings Directorate Regulations Division
Attention: Mr. C. Darling C. Dubé (957-2076)
  File No. F-3419

Interest Rate Protection Agreement ("IRPA")

This is in reply to your memorandum dated November 21, 1989 concerning a bank's entitlement to a reserve under subparagraph 20(1)(m)(ii) of the Income Tax Act in respect of fees it receives under an IRPA.

The Department of Finance confirmed to us that it does not have any tax policy concerns with respect to the position expressed in your memorandum.

B.J. Bryson Acting DirectorCurrent Amendments and Regulations Division

CD/jab