26 October 1992 External T.I. 9222715 F - Treasury Bills Owned By Non-Residents (6630)

By services, 7 July, 2022
Official title
Treasury Bills Owned By Non-Residents (6630)
Language
French
CRA tags
212(1)(b)(ii)(C)(I)
Document number
Citation name
9222715
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
650266
Extra import data
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"field_proprietary_citation": [],
"field_release_date_new": "1992-10-26 07:00:00",
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Main text
  5-922271
19(1) G. Middleton
  (613)957-2122

October 26, 1992

Dear Sirs:

This is in reply to your letter of July 24, 1992 in which you asked about the Canadian income tax treatment for Canadian treasury bills purchased by a resident and citizen of the United States.

With respect to Canadian treasury bills issued to non-residents after April 15, 1966, the difference between the discounted purchase price and the face value thereof is considered as interest and such interest is exempt from Canadian Part XIII withholding taxes by virtue of subclause 212(1)(b)(ii)(C)(I) of the Income Tax Act.

We hope these comments will be helpful.

Yours truly,

for DirectorReorganizations and Foreign DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch