Revenue Canada Taxation Head Office
M. Shea-DesRosiers 613) 957-8953
August 18, 1988
Dear Sirs:
This is in reply to your letter of August 10, 1988 wherein you have requested technical interpretations of the Income Tax Act with respect to mortgage bonds.
The situation you describe in your letter appears to relate to a specific proposed transaction and can accordingly be dealt with upon disclosure of all relevant facts (including the submission for examination of all relevant documents) and then only in the form of a request for an advance ruling. As pointed out in Information Circular 70-6R, dated December 18, 1978, a copy of which is enclosed, we do not offer opinion on proposed transactions. We are willing to issue a ruling if so requested in accordance with the above-mentioned circular.
Yours truly,
for Director Financial Industries Division Rulings Directorate