L. Burroughsford
Files: 11590-5; 11595-3; 11783-2
123(1)(q)
March 1995
XXXXX
This has reference to your January 11, 1995, ruling and interpretation letter to letter to XXXXX concerning certain mortgages, guarantees and administrative services supplied by the XXXXX As was previously verified, the Fund is a corporation and a mutual fund trust, the principal activity of which is the investing of funds on behalf of XXXXX Accordingly, the provision of administrative services in respect of the mortgages and guarantees fall within paragraph (q) of the definition of financial service, meaning they are taxable. The mortgages and guarantees supplied by XXXXX to the Fund currently enjoy exempt status under the Excise Tax Act.
However, you observed in your letter that the proposed amendment to paragraph (q) would seem to capture these otherwise exempt mortgages and guarantees as well, once it is passed into law and you have asked that, if this is indeed the case, we confirm this fact in writing.
We hope that these comments are of assistance to you. Should you have further questions, please do not hesitate to contact Duncan Jones at (613) 952-9210 or Linda Burroughsford at (613) 952-3413.
J. Sitka
A/Director
Financial Institutions and Corporate Reorganizations Division
GST Policy and Legislation
XXXXX
G. Bouchard-Forgues
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