CRA notes factors considered in deciding to backdate an HBP withdrawal

S. 146.01(2)(d) provides that for purposes of the home buyer plan rules in s. 146.01, a withdrawal from an RRSP made by an individual in January of a year “or at such later time as is acceptable to the Minister” is deemed to have been made at the end of the preceding year. When asked what factors CRA would consider in exercising this discretion, CRA mentioned, as the most likely:

• whether the RRSP balance at December 31, 2017 is sufficient to cover the subsequent RRSP withdrawal
• “the dates on which the amounts required for withdrawal were contributed” and
• “the reasons for the withdrawals being made over a period that straddled two calendar years” (e.g., a February closing)

Furthermore:

HBP participants who withdraw over more than one year will generally be contacted by the CRA to confirm details of their participation.

Neal Armstrong. Summary of 2018 APFF Financial Strategies and Instruments Roundtable, Q.8 under s. 146.01(2)(d).