26 January 1990 Income Tax Severed Letter 32901A F - Non-Resident Withholding Tax on Interest Payment

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

Subject: Advance Ruling Request   24(1)

Enclosed is a copy of a ruling request from the St. John's office of  24(1) along with a copy of our letter advising that the issue to be resolved involved completed (rather than proposed) transactions, and that such issues are within the responsibility of the District Office.

We note that the taxpayer's representative did not submit documentation sufficient to reach a conclusion 24(1)

In our opinion, the questions to be resolved are:

(1)     24(1)

(2)     If the answer to (1) is positive, does the non-resident have an amount receivable pursuant to a bond, debenture, note, mortgage, hypothec or similar obligation referred to in subclause 212(1)(b)(ii)(C)(I)?

If you wish to ask us to re-examine this matter after you gave obtained any other facts that may be available to you, we would be pleased to give it further consideration.

J.C. Clark ChiefLeasing & Financing SectionFinancial Industries DivisionRulings Directorate