XXXX
W.E. Douglas (613) 957-3496
Attention: XXXX
October 2, 1986
Dear Sirs:
In reply to your letter of September 17, 1986, it is our opinion that a Canadian bank's bond, debenture, mortgage, hypothec, note or similar obligation denominated in a foreign currency and issued through a foreign branch of the Canadian bank will not constitute foreign property within the meaning assigned to that expression by subsection 206(1) of the income Tax Act (the "Act").
Since the term "deposit note" is not defined in and for the purposes of the Act, it is a question of fact in each case whether a particular deposit note is a bond, debenture, mortgage, hypothec, note or similar obligation.
Yours truly,
for Director Financial Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch