24(1)
5-913516
N. Goldstein
(613) 957-8953
Attention: 19(1)
January 22, 1992
Dear Sir:
Re: Large Corporation Tax
We are writing in response to your letter of December 9, 1991, requesting a technical interpretation regarding the calculation of taxable capital pursuant to the provisions of subsection 181.2(3) of the Income Tax Act (the "Act"), and specifically, whether bankers' acceptances are included in the taxable capital of a corporation.
Subsection 84(1) of the Amendments to the Income Tax Act and Other Related Statutes, Draft Legislation, issued by the Minister of Finance in December, 1991 and announced on December 20, 1991 provides that paragraph 181.2(3)(d) of the Act is repealed and the following substituted therefor:
(d) the amount of all indebtedness of the corporation at the end of the year represented by bonds, debentures, mortgages, notes, bankers' acceptances or similar obligations.
Subsection 84(4) of the same Draft Legislation states that subsection 84(1) is applicable with respect to taxation years ending after the announcement date.
Accordingly, for taxation years ending after December 20, 1991, it is our position that bankers' acceptances must be included in calculating taxable capital for the purposes of subsection 181.2(3) of the Act.
We trust the foregoing comments are of assistance.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate