20 November 1996 T.I. 962883 (C.T.O. "Def'n of SFI")
Although a corporation that is a bank under the domestic laws of a country other than Canada but is not a bank listed in Schedule I or II of the Bank Act, would not qualify as a "bank" for purposes of the definition of specified financial institution, one would be required to consider on the basis of the facts whether the corporation qualified under one of the other paragraphs of the definition, for example, paragraph (e).
27 March 1991 T.I. (Tax Window, No. 1, p. 20, ¶1172)
A corporation which earns interest solely from investing in term deposits, T-bills and GIC's would not automatically be considered to fall within paragraph (e).
25 September 89 T.I. (February 1990 Access Letter, ¶1120)
A corporation, whose sole asset is a limited partnership interest in a partnership whose business is the lending of money to persons with whom it is dealing at arm's length, is a specified financial institution and a restricted financial institution.
28 May 1990 T.I. (October 1990 Access Letter, ¶1492)
Discussion of criteria for determining whether a partner is a specified member.