3 September 1997 Ruling HQR0000579

"A swap transaction falls under the definition of 'debt security' since the definition of debt security... includes 'a right to be paid money'."

"Revenue Canada takes the position that the service of 'arranging for' the supply of a financial service ... generally refers to the activities of an intermediary, such as a broker, a salesperson or a dealer, of bringing together in an active manner of two parties (a supplier and a recipient of the financial service) for the supply of the financial service by one person to the other. 'Arranging for' a service does not mean the service of 'recommending', 'advertising' or 'marketing' alone. The term 'arranging for' the service should go beyond the activities of merely referring or introducing one party to the other party for the supply of a financial service. In general, the intermediary will be expected to have spent time and effort to assist both parties whenever necessary for the eventual success of the supply of the financial service by one party to the other party."