Rev. Rul. 67-454

Revenue Ruling 67-196, C.B. 1967-1, 313, lists foreign corporations which have been issued rulings, pursuant to section 4920(b) of the Internal Revenue Code of 1954, exempting certain classes of stock from the interest equalization tax. Subsequent to the publication of that ruling, Surluga Gold Mines Limited has notified the Service that it will issue nonexempt shares that will not be easily identifiable from the exempt shares. Held , Revenue Ruling 67-196 is hereby modified by the deletion of `Surluga Gold Mines Limited-common stock' from the listing.

The revocation of the Internal Revenue Service's ruling with respect to Surluga's common stock does not invalidate the exemption provided by section 4920(b) of the Code. If a United States person can establish that the shares acquired are shares which do meet the requirements of section 4920(b) of the Code, such an acquisition will not be subject to the interest equalization tax.