CRA accepts withholding tax exemption on interest paid on undivided interests in mortgages
28 November 2012 - 9:30am
In a heavily redacted ruling (20 of the 21 paragraphs describing the proposed transactions were deleted!) CRA indicated that interest paid on instruments representing undivided interests in pools of mortgages (presumably, CMHC-guaranteed) represented "fully exempt interest." This seems to imply that CRA accepts that a co-ownership interest in a mortgage qualifies as a "bond, debenture, note, mortgage, hypothecary claim or similar debt obligation."
Neal Armstrong. Summary of 2012 Ruling 2011-0431891R3 under s. 212(3) - fully exempt interest.