1 December 1989 Internal T.I. ACI3419 F - Interest Rate Protection Agreement

By services, 7 July, 2022
Official title
Interest Rate Protection Agreement
Language
French
CRA tags
20(1)(m)(ii)
Document number
Citation name
ACI3419
Severed letter type
Technical Interpretation - Internal
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
649399
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1989-12-01 07:00:00",
"field_tags": []
}
Main text

December 1, 1989

Mr. R.A. Short
General Director
Tax Policy and Legislation Branch BY HAND
Department of Finance
140 O'Connor Street C. Dubé
L'Esplanade Laurier 957-2076
16th Floor, East Tower I-3419
Ottawa, Ontario K1A 0G5

Dear Al:

Re:  Interest Rate Protection Agreement ("IRPA")

We are enclosing a copy of a November 21, 1989 memorandum from our Financial Industries Division (the "Division") which has been asked to express an opinion as to whether a bank is entitled to a reserve under subparagraph 20(1)(m)(ii) of the Income Tax Act ("Act") in respect of fees it receives under IRPAs extending beyond one year.  The memorandum summarizes the characteristics and the purpose of the agreement.

23

Would you please advise us to whether you have any tax policy concerns with respect to the interpretation that our Division proposes to adopt.

We would appreciate a response as soon as possible.

Yours sincerely,

B.J. BrysonActing DirectorCurrent Amendments andRegulations Division