Mail Stop 3-8

				May 25, 2005

By Facsimile and U.S. Mail

Russell Girling
Chief Financial Officer
TransCanada Corporation
450 - 1st Street SW
Calgary, AB T2P5

		Re:	TransCanada Corporation
			File No. 1-31690
			Form 40-F for the year ended December 31, 2004

			TransCanada Pipelines LTD
			File No. 1-08887
			Form 40-F for the year ended December 31, 2004

Dear Mr. Girling:

	We reviewed your responses to our prior comments on the above
referenced filings as set forth in your letter dated May 13, 2005.
Our review resulted in the following accounting comment.

Form 40-F for the Year Ended December 31, 2004

1. We note your response to comment 3 of our letter dated April
22,
2005.  It appears that EITF 88-18 is not applicable to the
accounting
for the sale Power LP units as EITF 88-18 addresses sales of
future
revenues or income.  In your situation, a subsidiary sold equity
shares that you agreed to repurchase at a future date.  The
accounting for your transaction appears to be more appropriately
addressed in question 2 of SAB Topic 5:H.  Given the materiality
of
the amounts recognized in earnings under US GAAP, please amend the
note to your financial statements included as part of your 2004
Form
40-F to eliminate gains associated with the Power LP transactions
from 1997 through 2003.



	```````````````````````````````````````````````As
appropriate,
please respond to this comment within 10 business days or tell us
when you will provide us with a response.  Please provide us with
a
response letter that keys your response to our comment and
provides
any requested supplemental information.  Please file your response
letter on EDGAR as a correspondence file.
`
		If you have any questions regarding this comment, please
direct them to Robert Babula, Staff Accountant, at (202) 551-3339
or,
in his absence, to the undersigned at (202) 551-3841.  Any other
questions regarding disclosures issues may be directed to H.
Christopher Owings, Assistant Director at (202) 551-3725.

			Sincerely,



			Michael Moran, Esq.
			Branch Chief


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Russell Girling
TransCanada Corporation
May 25, 2005
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