Kevin Donnelly (613)957-3500
May 27, 1988
Dear Sir:
In reply to your letter of April 28, 1988 concerning the interpretation of the words "borrowed money" as used in the Notice of Ways and Means Motion tabled in the House of Commons on June 2, 1987, we agree with your conclusion that technically the deduction for interest on borrowed money would not extend to interest on Notes issued to shareholders in payment of a dividend in kind.
Yours truly,
for Director Financial Industries Division Rulings Directorate