REVENUE CANADA TAXATION
INTERPRETATION BULLETIN
NUMBER: IT-155R3
DATE: March 26, 1993
SUBJECT: SPECIAL RELEASE
Exemption from Non-Resident Tax on Interest Payable on Certain Bonds,
Debentures, Notes, Hypothecs or Similar Obligations
Application
The purpose of this Special Release is to update IT-155R3 dated June 16,
1989.
Bulletin Revisions
1. Delete the last sentence of paragraph 1.
2. Replace paragraph 2 with the following:
2. The expression "guaranteed by the Government of Canada" refers to a
guarantee given under the authority of Parliament to fulfil or partially
fulfil the obligations of a person in case of default. Interest paid on
obligations of, or guaranteed by, a Crown corporation (or a board, commission
or other body) that can be regarded as the Government of Canada by virtue of
its enabling legislation is also exempt from the non-resident tax when paid
or credited to a person not resident in Canada. Examples of such entities are
the Canadian Wheat Board, the Federal Business Development Bank and the
Export Development Corporation. Canadian National Railways is an example of a
Crown corporation which is not regarded as the Government of Canada.
If you have any comments regarding the matters discussed in this bulletin,
please send them to:
Director, Technical Publications Division
Legislative and Intergovernmental Affairs Branch
Revenue Canada, Taxation
875 Heron, Road
Ottawa, ON K1A 0L8
