CRA accepts that shares of mortgage corporations generally are not taxable Canadian property

CRA considers that the shares of a private corporation holding mostly undefaulted mortgages on Canadian properties do not derive their value more than 50% from the real estate, so that such shares are not taxable Canadian property.

Neal Armstrong.  Summary of 13 September 2012 CICA Compliance Conference, 2012-0453021C6: under s. 248(1) - taxable Canadian property.