Section 33.1

Subsection 33.1(1)

Eligible Loans

Administrative Policy

1 December 1992 T.I. (Tax Window, No. 27, p. 15, ¶2347)

It is a question of fact whether existing loans booked in Canada or offshore that are renegotiated, refinanced or rolled over constitute new loans that can be booked in an international banking centre.

"Gold bullion and gold certificates do not constitute eligible deposits or eligible loans."

26 June 1992 T.I. 920271 (December 1992 Access Letter, p. 12, ¶C20-1136)

Re the eligibility of loans made by an IBC to a non-resident buyer for the purpose of financing the importation of Canadian goods and services to the foreign buyer's country.

"Discussion of financial instruments that are eligible capital loans where the IBC was the first lender."

26 April 1991 Memorandum (Tax Window, No. 2, p. 29, ¶1218)

Where a loan is acquired from a foreign bank, the reasonable enquiries as to the use of the loan proceeds should be made in respect of the time the loan is acquired by the international banking centre rather than at the time the loan was made.

Non-Resident Person

Administrative Policy

26 June 1992 T.I. 920271 (December 1992 Access Letter, p. 12, ¶C20-1136)

Shipping companies to which s. 250(6) applies are non-residents for purposes of s. 33.1.

Subsection 33.1(4)

Administrative Policy

30 September 1992 T.I. (Tax Window, No. 24, p. 11, ¶2230)

Discussion of various issues arising under s. 33.1.

Subsection 33.1(9)