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S3-F10-C1- Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Subsection 146.2(6) Summary Under Tax Topics- Income Tax Act- Section 146.2- Subsection 146.2(6) Option trading and short selling 1.90 As discussed in ¶ 1.41 and ¶ 1.46, where a registered plan engages in certain option writing strategies or foreign exchange trading, it may be considered to be carrying on a business. ... Note that, because the restriction on borrowing for TFSAs (discussed in ¶ 1.83) applies to any property not just money, a short sale within a TFSA is effectively prohibited. 1.91 The decision in Prochuk v The Queen, 2014 TCC 17, 2014 DTC 1050 held that trading in a registered plan is not a relevant factor in determining whether a taxpayer is carrying on a trading business outside of the plan. ...

S3-F10-C1- Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 204- Qualified Investment- Paragraph (a) Digital currency and FX contracts excluded 1.12... ... While such a deposit is generally not a qualified investment, the CRA will not apply the adverse income tax consequences described in ¶ 1.69- 1.80 if the deposit is left with the broker for no more than a few days. FX qualifies as money 1.46 Foreign currency is generally a qualified investment, as discussed in ¶ 1.12 [re money]. ...

S3-F10-C1- Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 204- Qualified Investment- Paragraph (d) Listing must be unconditional 1.20 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. ... Other FX contracts not qualified 1.46 Foreign currency is generally a qualified investment, as discussed in ¶ 1.12. Foreign exchange contracts that are listed on a designated stock exchange are also qualified investments if the holder’s risk of loss does not exceed the holder’s cost (see ¶ 1.16). ...

S3-F6-C1- Interest Deductibility-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Capitalization of interest not treated as payment thereof 1.83 In circumstances where accrued interest is added to the outstanding principal amount of an existing loan resulting in a new obligation or novation, an interest payment will not be considered to have been made. ...

S3-F10-C1- Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Paragraph 4900(1)(j) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(1)- Paragraph 4900(1)(j) Acquisition of real estate on default 1.34 Real or immovable property is not a qualified investment for a registered plan. ... In this case, the CRA will not apply any adverse tax consequences (as described in ¶ 1.69- 1.80) provided the property is offered for sale under reasonable conditions and sold within one year. ...

S3-F10-C3- Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Subparagraph (a)(v) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (a)- Subparagraph (a)(v) 3.12 Fee waivers, preferential pricing, bonus interest and other promotional incentives offered by financial institutions typically satisfy one or more of the exceptions in (a)(i), (ii) and (v), e.g.: Example 3 A financial institution offers a free tablet to new clients who open a TFSA or RRSP and maintain a minimum account balance of $10,000 for at least six months. ... Example 5 A credit union waives the monthly fee for chequing accounts for customers who have at least five products (RRSPs, RRIFs, RESPs, RDSPs, and TFSAs) with it – there is no specified minimum balance. ...

S3-F10-C3- Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Premium Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Premium Example 6, para. 3.12 [cash incentive to open RRSP or TFSA account] No s. 207.01 advantage if a financial institution pays $100 in cash directly to the plan of new customers who open an RRSP, RRIF or TFSA and maintain a minimum balance of $50,000 for at least one year, and the incentive can be paid into the plan of the customer's choosing if each plan exceeds the $50,000 minimum. CRA also states that the payments “do not constitute a premium, gift, or contribution to the plan (as they are considered a return on investment).” 3.36-3.37 [dealer reimbursement for deferred redemption charge] Where in order to encourage an investor to switch from another mutual fund company, a dealer will reimburse for any deferred sales charge incurred on the sale of the old funds, the payment of the rebate into the plan will not constitute a premium, gift or contribution to the plan – and will also not constitute an advantage, provided that the rebate is determined in a normal investment context without regard to the tax attributes of the individual’s registered and non-registered account(s). ...

S3-F10-C1- Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Paragraph 4900(1)(e) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(1)- Paragraph 4900(1)(e) Writing puts and calls not subject to rules 1.40 When writing put and call options..., no property is actually acquired by the option writer at the time the option is sold besides the option premium.... ... As noted in ¶ 1.15, if the deposit is left with the broker for longer than a few days, the deposit would not be a qualified investment.... ...

S3-F10-C3- Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Subparagraph (b)(i) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(i) 3.22 Example 10 (bid/ask plan strip) Two unrelated individuals effectively transfer all the value in their RRSP to their TFSA by having their TFSA continually buy securities from the other’s RRSP at the bid price and sell them back to the other’s RRSP at the ask price. These would give rise to advantages under (b)(i) and would also be a registered plan strip. 3.36-3.37 [dealer reimbursement for deferred redemption charge] Where in order to encourage an investor to switch from another mutual fund company, a dealer will reimburse for any deferred sales charge incurred on the sale of the old funds, the payment of the rebate into the plan will not constitute a premium, gift or contribution to the plan – and will also not constitute an advantage, provided that the rebate is determined in a normal investment context without regard to the tax attributes of the individual’s registered and non-registered account(s). 3.41 Example 12 (non-pro rata fund rebates) A mutual fund dealer convinces an individual to switch mutual fund companies and agrees to share 40% of the 5% sales commission he will earn on the purchase of the new funds. ...

S3-F10-C1- Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under unattached ...