Section 20.2

Subsection 20.2(1) - Interest — authorized foreign bank — interpretation

Administrative Policy

1996 Corporate Management Tax Conference Round Table, Q. 1

It is RC's understanding that provisions of proposed s. 20.2 are intended to codify RC's administrative position. Also, representatives of the Department of Finance have publicly stated that, to the extent that the new provisions prove to be more restrictive than the existing administrative position, the new provisions will be modified to eliminate those discrepancies.

Subsection 20.2(3) - Interest deduction

Articles

Orest Moysey, Stan Mag, "New Canadian Branch Making Rules for Foreign Banks: Opportunities and Issues", International Tax Planning, 2000 Canadian Tax Journal, Vol. 48, No. 6, p. 1869.