10 April 1990 Income Tax Severed Letter ACC9189 - Sovereign Immunity

Jim Wilson
             19(1)                      613-957-2063
                                        HBW 9412-2-3
                                        EACC 9189

April 10, 1990

Dear 19(1)

Re:              24(1)

Sovereign Immunity

We are writing in reply to your letters dated January 30, 1989, and
February 20, 1989, in which you requested a sovereign immunity
exemption for the     24(1)   .  You may provide photostatic copies
of this letter to paying or disbursing agents as their authority to
make payments of investment income to the     24(1)     without
withholding Canadian non-resident tax.  In the event taxes have
already been withheld, provide a photostatic copy of this letter
with the NR7-R refund application.

This exemption is granted pursuant to the Doctrine of Sovereign Immunity and is subject to the conditions contained in paragraph 47 of Information Circular 77-16R3 (copy enclosed).

We are of the understanding that     24(1)    will provide Revenue
Canada, Taxation with an annual list of Canadian investments to
which this exemption applies.

Our division is presently reviewing the Department's policies and procedures with respect to the issuance of letters confirming sovereign immunity. Accordingly, the authorization for exemption from tax as described above expires on December 31, 1990. At that time a re-application for sovereign immunity should be made.

We trust you will find this to your satisfaction.

Yours sincerely, A/Director Provincial and International Relations Division