Revenue Canada Taxation Head Office
M. Shea-DesRoéiers (613)957-8953
September 8, 1988
Dear Sirs:
Re: Qualified Investment Self-Directed Registered Retirement Savings Plans ("RRSP")
This is in reply to your letter of August 16, 1988 with a copy of a promissory note attached concerning the above-mentioned subject.
You enquire as to whether the following instrument is an eligible investment under a self-directed RRSP.
Instrument: Promissory Note guaranteed by the XXXX in bearer form
or registered.Issuer: An Ontario University, Community College or Community (Public)
Hospital.
Term: One day to five years.Amount: No minimum or maximum restrictions.
Yield: Market or as determined by issuer.
Provided that the issuer (Ontario University, Community College or Community (Public) Hospital) is a Canadian corporation as defined in paragraph 89(1)(a) of the Income Tax Act and the promissory note meets the requirements of paragraph 4900(1)(i) of the Income Tax Regulations, the instrument would, in our view, be a qualified investment for the purposes of subparagraph 146(l)(g)(iv) of the Income Tax Act.
We trust the above comments will be of assistance to you.
Yours truly,
for Director Financial Industries Division Rulings Directorate