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