| August 24, 1990 | |
| VANCOUVER DISTRICT OFFICE | Head Office |
| S. McKenzie | C. Tremblay |
| Chief of Audit | (613) 952-1361 |
| EACC9268 |
We are writing this memorandum to advise you that we have been asked by 19(1) our views with respect to corporations owned by Indian Band Councils. She is of the opinion that her client's band council is a municipality and that corporations owned 90% by Indian bands qualify for tax exemption under paragraph 149(1)(d). This view is contrary to our position. Her enquiries and our responses are included for your information. We do not have the name of a particular corporation, owned by an Indian Band, in respect of which she may be seeking an exemption under paragraph 149(1)(d) of the Act. We presume, however, that one or more taxpayers will claim an exemption.
for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch