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This would result in the following payments: $1,000 to the TFSA (40% × 5% × $50,000); $5,000 to the RRSP (40% × 5% × $250,000); and $4,000 to the taxable account (40% × 5% × $200,000). ... This means that the initial TFSA advantage is $1,500 ($2,500 – (40% × 5% × $50,000)). The initial RRSP advantage is $2,500 ($7,500 – (40% × 5% × $250,000)). ...

These rules are discussed in Income Tax Folio S3-F10-C2, Prohibited Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs and Income Tax Folio S3-F10-C3, Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs. ... See ¶ 1.83 and ¶ 1.86 for more details. Annuity contracts 1.47 Several types of annuity contracts are qualified investments, although some are eligible only for certain registered plans. ... Specific statutory or regulatory authority for each type of qualified investment Chapter reference Type of qualified investment (QI) Statutory or regulatory authority ¶ 1.12 money, Canadian or foreign-denominated paragraph (a) of the QI definition in section 204 ¶ 1.13 deposit with bank or trust company paragraph (a) of the QI definition in section 204 ¶ 1.14 deposit with credit union Regulation 4900(1)(g) ¶ 1.16 listed security paragraph (d) of the QI definition in section 204 ¶ 1.22 American Depository Receipt Regulation 4900(1)(w) ¶ 1.23 share of public corporation Regulation 4900(1)(b) ¶ 1.23 debt of public corporation Regulation 4900(1)(c.1) ¶ 1.25 unit of mutual fund trust Regulation 4900(1)(d) ¶ 1.26 share of mutual fund corporation Regulation 4900(1)(b) ¶ 1.27 share or unit of registered investment Regulation 4900(1)(a) ¶ 1.29 share of mortgage investment corporation Regulation 4900(1)(c) ¶ 1.30(a) debt of Government of Canada paragraph (b) of the QI definition in section 204 ¶ 1.30(b) debt of province, municipality or Crown corporation paragraph (b) of the QI definition in section 204 ¶ 1.30(c) debt of Canadian-listed corporation, mutual fund trust or limited partnership paragraph (c) of the QI definition in section 204 ¶ 1.30(d) debt of foreign-listed corporation paragraph (c) of the QI definition in section 204 ¶ 1.30(f) bankers' acceptance Regulation 4900(1)(i.2) ¶ 1.30(g) debt of authorized foreign bank paragraph (c) of the QI definition in section 204 ¶ 1.30(h) investment grade debt paragraph (c.1) of the QI definition in section 204 ¶ 1.30(i) mortgage-backed security Regulation 4900(1)(j.2) ¶ 1.33 arm’s-length mortgage Regulation 4900(1)(j) ¶ 1.36 non-arm’s-length mortgage Regulation 4900(1)(j.1) ¶ 1.38 unlisted warrants and options Regulation 4900(1)(e) ¶ 1.48 segregated fund annuity contracts paragraph (c.1) of the QI definition in subsection 146(1), paragraph (c) of the QI definition in subsection 146.1(1), paragraph (b.1) of the QI definition in subsection 146.3(1), paragraph (b) of the QI definitions in subsections 146.4(1) and 207.01(1) ¶ 1.49 RRSP annuity paragraph (c) of the QI definition in subsection 146(1) ¶ 1.50 qualified annuity paragraph (c.2) of the QI definition in subsection 146(1), paragraph (b.2) of the QI definition in subsection 146.3(1) and paragraph (c) of the QI definition in subsection 146.4(1) ¶ 1.51 gold and silver coins, bullion and certificates Regulation 4900(1)(t), (u) and (v) ¶ 1.55 small business investments Regulation 4900(6) and (14) Application This updated Chapter, which may be referenced as S3-F10-C1, is effective May 28, 2024. ...

The qualified investment rules are discussed in Income Tax Folio S3-F10-C1, Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs and the advantage rules are discussed in Income Tax Folio S3-F10-C3, Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs. ... There are also three categories of excluded property, notably insured mortgages or hypothecs (see ¶ 2.18). ... The transitional rules described in ¶ 2.28(b) and in ¶2.34 also apply to RESPs and RDSPs. ...

Other specific provisions – In addition to section 67.6, a fine or penalty may be precluded from deduction by: paragraph 18(1)(t) – Payments under different Acts (see ¶ 1.23); section 67.5 – Non-deductible illegal payments (see ¶ 1.28). The following specific provisions may also be relevant: subsection 18(9.1) – prepayment penalties (see ¶ 1.30); subsection 62(3) – eligible moving expenses (prepayment penalties) (see ¶ 1.38). 1.3 The deductibility of a fine or penalty can only be determined after examining all the relevant facts. ... See ¶ 1.30 for more information concerning the income tax treatment of prepayment penalties. ...

Variable A 2.109 Variable A can be a positive or negative amount and is determined by its own formula: C + D + E + F – G where: C = the positive or negative balance of the corporation’s GRIP at the end of the preceding tax year. ... As described in ¶2.55, the term non-CCPC is used in this Chapter to describe a corporation that is neither a CCPC nor a DIC. 2.121 More specifically, under the definition of LRIP in subsection 89(1), the LRIP of a non-CCPC in a particular tax year is the amount determined by the formula: (A + B + C + D + E + F) – (G + H) where: A = the balance of the corporation’s LRIP at the end of the preceding tax year. ... The amount included in the parent corporation’s LRIP is equal to the subsidiary corporation’s LRIP immediately before the end of that last tax year. 2.153 If the subsidiary corporation was a CCPC in its last tax year, the amount included in the parent corporation's LRIP under paragraph 89(10)(b) is determined by the formula: A + B + C – D – E – F – G – H This formula is based on a tax-balance-sheet approach. ...

Table of contents Discussion and interpretation Overview of the capital dividend account Capital dividend account – private corporation qualification Capital dividend account – election Election under subsection 83(2) and its effects Late-filed elections Capital dividend account – components General discussion of the CDA balance determination CDA Component 1 – non-taxable portion of capital gains CDA Component 2 – capital dividends received by the corporation CDA Component 3 – eligible capital amounts CDA Component 4 – life insurance policy proceeds CDA Component 5 – trust distributions CDA Component 6 – capital dividends payable Special rules Amalgamation or winding-up Payments in kind and deemed dividend payments Excessive elections Overstatements Additional tax on excessive elections Election to avoid additional tax Anti-avoidance rule Application Reference History Discussion and interpretation Overview of the capital dividend account 1.1 This section will give the reader an overview and general description of the capital dividend account (CDA) and the mechanism to pay tax-free dividends from that account. ... CDA Component 5 – trust distributions 1.73 This paragraph has been deleted. ... The non-deductible portion of the capital loss of Corporation B is $75,000. $50,000 – $75,000 = – $25,000 Component 1 = NIL (because Component 1 cannot be a negative amount) Component 3 Amount included in income of Corporation A pursuant to paragraph 14(1)(b) (see ¶ 1.54) Component 3 = $25,000 Component 4 Net proceeds of a life insurance policy received by Corporation B Component 4 = $40,000 Calculation of CDA balance of Amalco: Component 1 + Component 3 + Component 4 = $65,000 In the first tax year after amalgamation, Amalco realizes a capital gain of $90,000, the non-taxable portion of which is $45,000. ...

See ¶ 1.24 for more information relevant to individuals ceasing to be resident in Canada. ... Deemed residents of Canada- subsection 250(1) Subsection 250(1) – overview 1.30 An individual who is resident in Canada on the basis of the factors discussed in ¶ 1.10 to 1.15 or ¶ 1.25 to 1.27-- that is, a factual resident of Canada-- cannot be a deemed resident of Canada under subsection 250(1). ... Thereafter, residence will depend on the factors outlined in ¶ 1.10 to 1.21. ...

Under paragraph 402(3)(a) (see also ¶2.17 and ¶2.18), the corporation’s taxable income earned in the year in a province equals 1/2 the total of: the proportion of the corporation’s taxable income for the year that the gross revenue for the year reasonably attributable to the permanent establishment in the province is of its total gross revenue for the year, and the proportion of the corporation’s taxable income for the year that the total salaries and wages paid in the year by the corporation to employees of the permanent establishment in the province is of the total salaries and wages paid in the year by the corporation. 2.16 The allocation of a corporation’s taxable income attributable to a province for a tax year can be illustrated by the following formula: TI × [½ × (A/B + C/D)] Where: TI – is the corporation’s taxable income for the year; A – is the corporation’s gross revenue for the year that is reasonably attributable to the permanent establishment in the province; B – is the corporation’s total gross revenue for the year; C – is the salaries and wages paid in the year by the corporation to employees of the permanent establishment in the province; and D – is the total salaries and wages paid in the year by the corporation. ... It has the following amounts for a particular tax year: TI – Taxable income for the year: $100,000 B – Total gross revenue for the year: $500,000 D – Total salaries and wages paid in the year: $250,000 ACo has the following amounts attributable to one particular province for the tax year: A – Gross revenue for the year reasonably attributable to the permanent establishment in the province: $250,000 C – Salaries and wages paid in the year to employees of the permanent establishment in the province: $150,000 ACo’s taxable income allocated to the particular province is computed as follows: TI × [½ × (A/B + C/D)] = $100,000 ×[½ × ($250,000/$500,000 + $150,000/$250,000)] = $55,000 Therefore, ACo’s taxable income allocated to the particular province is $55,000. 2.17 When a corporation with a permanent establishment in a particular province and a permanent establishment outside that province has gross revenue of nil for a tax year, paragraph 402(3)(b) of the Regulations applies to calculate the taxable income attributable to that province. ... Example 3 – Central paymaster rules Corporation A provides services to its subsidiary companies. ...

Reduce by the principal residence exemption based on the formula A × (B ÷ C), where: A is $65,000 B is 1 + 21 (being tax years 1975 to 1995) C is 22 (being tax years 1975 to 1996) = $65,000 × (22 ÷ 22) = $65,000 Gain is therefore NIL. ... Alternative method – calculation of maximum total net gain: Maximum total net gain = pre-1982 gain + post-1981 gain – post-1981 loss Pre-1982 gain: Gain otherwise determined is $10,000 (that is, $30,000 – $20,000) Reduce by the principal residence exemption based on the formula A × (B ÷ C), where: A is $10,000 B is 1 + 3 (being tax years 1979 to 1981) C is 7 (being tax years 1975 to 1981) = $10,000 × (4 ÷ 7) = $5,714 Gain is therefore $4,286 Post-1981 gain: Gain otherwise determined is $35,000 (that is, $65,000 – $30,000) Reduce by the principal residence exemption based on the formula A × (B ÷ C), where: A is $35,000 B is 6 (being tax years 1996 to 2001) C is 20 (being tax years 1982 to 2001) = $35,000 × (6 ÷ 20) = $10,500 Gain is therefore $24,500 Post-1981 loss: Not applicable Maximum total net gain = pre-1982 gain + post-1981 gain – post-1981 loss = $4,286 + $24,500 – Nil = $28,786. ... X’s 2001 gain on the cottage are as follows: Usual method for calculating gain: Gain otherwise determined is $45,000 (that is, $65,000 – $20,000) Reduce by the principal residence exemption based on the formula A × (B ÷ C), where: A is $45,000 B is 1 + 20 (being tax years 1979 to 1992 and 1996 to 2001) C is 27 (being tax years 1975 to 2001) = $45,000 × (21 ÷ 27) = $35,000 Gain is therefore $10,000 Alternative method – calculation of maximum total net gain: Maximum total net gain = pre-1982 gain + post-1981 gain – post-1981 loss Pre-1982 gain: Gain otherwise determined is $10,000 (that is, $30,000 – $20,000) Reduce by principal residence exemption based on the formula A × (B ÷ C), where: A is $10,000 B is 1 + 3 (being tax years 1979 to 1981) C is 7 (being tax years 1975 to 1981) = $10,000 × (4 ÷ 7) = $5,714 Gain is therefore $4,286 Post-1981 gain: Gain otherwise determined is $35,000 (that is, $65,000 – $30,000) Reduce by principal residence exemption based on the formula A × (B ÷ C), where: A is $35,000 B is 17 (being tax years 1982 to 1992 and 1996 to 2001) C is 20 (being tax years 1982 to 2001) = $35,000 × (17 ÷ 20) = $29,750 Gain is therefore $5,250 Post-1981 loss: not applicable Maximum total net gain = pre-1982 gain + post-1981 gain – post-1981 loss = $4,286 + $5,250 – Nil = $9,536 Result: Although Mr. ...

At the end of Year 2, Paul has outstanding shareholder loans owing to Company G calculated as follows: $25,000 ‑ $14,000 ‑ $2,000 = $9,000. ... At the end of Year 4, Paul’s outstanding car loan balance is calculated as $45,000 ‑ $1,500 November rent ‑ $1,500 December rent = $42,000. ... This amount is calculated as follows: $27,000 in Year 4 loans and debts + $18,000 in Year 5 loans = $45,000. ...