February 13, 1992
Principal Issue
We received a ruling request asking that we rule that a swap transaction could form part of the calculation of income or loss from an international banking centre ("IBC") business.
We concluded that we could not rule as the income from an IBC business is only to be the income or loss derived from eligible loans as that term is defined in subsection 33.1(1). We concluded that a swap is a separate transaction from an eligible loan.
An opinion letter was given instead that indicated that the swap was to be considered in determining the income or loss of the bank and that the costs or revenues associated with such a swap were generally to be deductible or included in such income.