9 December 1988 Income Tax Severed Letter 5-7081 - [Definition of term foreign property]

By services, 22 July, 2022
Official title
[Definition of term foreign property]
Language
English
Document number
Citation name
5-7081
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657218
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1988-12-09 07:00:00",
"field_tags": []
}
Main text

XXXX

F. Francis (613)957-3496

Attention: XXXX

December 9, 1988

Dear Sirs:

In reply to your letter of November 14, 1988, we concur with your position that a guarantee given by a non-resident person in respect of a note, bond or other similar obligation issued by a Canadian resident corporation would not be "foreign property" as that term is defined under paragraph 206(1)(g) of the Income Tax Act.

The above comments are an expression of opinion only and are not binding on the Department.

Yours truly,

for Director Financial Industries Division Rulings Directorate