CRA states that an exchange listing does not count until it becomes unconditional
In its new Folio on qualified investments for registered plans such as RRSPs, CRA states:
In a new public issue of securities, the listing of the securities may be delayed for a short period of time pending fulfillment of certain conditions. A security that is approved for listing or that has a conditional approval for listing is not at that time considered to be listed on a designated stock exchange. In order for a security to qualify, the listing must be full and unconditional.
Since it is common for the listing to still be conditional at the time the shares or units in question are first issued, it would be safer to try to rely, if possible, on their qualification as shares or units of a public corporation or mutual fund trust, as applicable (including potentially under the relevant look-back rules).
Other departures or additions from IT-320R3 include:
- Bitcoins are not money.
- “[C]ash on deposit with a broker…is generally not a qualified investment, [but] the CRA will not apply… adverse income tax consequences…if the deposit is left with the broker for no more than a few days.”
- The AIM and Alternext systems are not designated stock exchanges.
- A subsidiary or affiliate of one of the listed rating agencies will be accepted if the “corporate structure and legal relationship make it clear that a listed rating agency recognizes and would stand by the rating given by its subsidiary or affiliate.”
- An undivided interest in a strip coupon qualifies assuming the underlying bond qualifies.
- Gold or silver certificates issued by the Royal Canadian Mint could qualify.
- CRA will accommodate inadvertent and short-term RRSP etc. overdrafts.
- Day trading by an RRSP of qualified investments is acceptable. As for TFSAs, Prochuk "does not stand for the proposition that the trading of securities in a registered plan will not in any circumstance be considered to be carrying on a business by the plan.”
Neal Armstrong. Summaries of S3-F10-C1 under s. 204 - qualified investment - para. (a), s.262 , s.204 - qualified investment (d) , Reg. s. 4900(1)(b), s. 204.4(1), Reg. s. 4900(2), Reg. s. 4900(1)(j), Reg. s. 4900(1)(j.1), s. 204 - qualified investment - (b), Reg. s. 4900(1)(e), s. 207.01(1) -advantage- (b), Reg. s. 4900(1)(u), Reg. s. 4900(1)(v), Reg. 4901(1) specified small business corporation, Reg. s. 5100-eligible corporation, s. 207.04(4), s. 146(10.1), s. 207.01(6), s. 146(4)(a), s. 146(4)(b), s. 146.2(6)