17 November 1989 Income Tax Severed Letter ACC8463 - Doctrine of Sovereign Immunity

By services, 22 July, 2022
Official title
Doctrine of Sovereign Immunity
Language
English
Document number
Citation name
ACC8463
Severed letter type
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657065
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1989-11-17 07:00:00",
"field_tags": []
}
Main text
19(1)                                        E.E. Campbell
                                             (613) 957-2067

November 17, 1989

Dear 19(1)

Re: 24(1)

We have your letter of October 24, 1989 regarding the above noted.

As indicated in our letter to you of July 26, 1989 we have recognized the above-noted for an exemption under the Doctrine of Sovereign Immunity. The exemption is subject to the conditions outlined in paragraph 47 of Information Circular 77-16R3, a copy of which was sent to you. It is still not clear what you are requesting of us. As stated in the Information Circular, we will give written authorization to a Canadian resident payer not to withhold tax in respect of investment income that is the property of the government or central bank of a foreign country.

If you are acting as an agent for the 24(1) in placing funds on deposit with Canadian residents or in investing in securities of Canadian companies and re requesting authorization for the Canadian resident payer not to withhold, you should provide us with a copy of the agreement between yourself and the 24(1).

Yours sincerely

C. Savage A/Director Provincial and International Relations Division

EEC/sg no2-247 File copy Sequence File Author's copy Chrono file (2) Reading file