Section 146

Table of Contents

Subsection 146(1) - Definitions

Earned Income

Cases

Androwich v. The Queen, 90 DTC 6084 (FCTD), briefly aff'd 93 DTC 5275 (FCA)

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Wood v. The Queen, 85 DTC 5552, [1985] 2 CTC 16 (FCTD)

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Words and Phrases
salary or wages

See Also

Goldstein v. The Queen, 96 DTC 1029 (TCC)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Estoppel 105

Administrative Policy

10 October 2014 APFF Roundtable, 2014-0538241C6 F - 75(2) and definition of "earned income" in 146(1)

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Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.6) basis adjustment for denied capital loss (otherwise subject to s. 75(2) attribution) at trust level 202
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) character preservation of attributed income/basis adjustment for denied capital loss at trust level 424

10 July 2013 Internal T.I. 2013-0478851I7 - Earned income for RRSP purposes

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3 August 1994 Memorandum 941939 (C.T.O. "Earned Income and Exempt Income for RRSP")

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24 February 1992 Memorandum (Tax Window, No. 13, p. 19, ¶1618)

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19 February 1992 Memorandum (Tax Window, No. 16, p. 15, ¶1755)

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11 December 1990 T.I. (May 1990 Access Letter, ¶1231)

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Premium

Administrative Policy

3 October 1996 T.I. 962856 (C.T.O. "RRSP Administration & Investment Management Fees")

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Qualified Investment

Administrative Policy

1 June 1993 External T.I. 5-930642 -

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13 January 1993 T.I. 923286 (November 1993 Access Letter, p. 508, ¶C180-151)

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25 March 1992 T.I. (Tax Window, No. 18, p. 18, ¶1830)

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23 January 1992 T.I. (Tax Window, No. 16, p. 15, ¶1714)

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91 C.R. - Q.40

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13 June 1991 T.I. (Tax Window, No. 4, p. 29, ¶1304)

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IT-320R2 "Registered Retirement Savings Plans - Qualified Investments"

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(5) 0

Articles

Singer, "Mortgages with Equity Tickers May Qualify as RRSP Investment", Taxation of Executive Compensation and Retirement, May 1990, p. 283.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(10) 55

Singer, "RRSPs Can Invest in a Wide Range of Fixed Income Securities", Taxation of Executive Compensation and Retirement, May 1990, p. 286.

Singer, "RRSPs Can Invest in a Wide Range of Equities", Taxation of Executive Compensation and Retirement, April 1990, p. 259

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(9) 53

Refund of Premiums

Administrative Policy

11 July 2016 External T.I. 2015-0592681E5 F - RRIF Death of an annuitant

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146.3 - Subsection 146.3(1) - Annuitant surviving spouse who has been predesignated can qualify as an RRIF annuitant even if he or she does not receive any annuity payments 243
Tax Topics - Income Tax Act - Section 146.3 - Subsection 146.3(6.2) deduction for transfer to eligible recipient by surviving spouse 277
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(l) transfer by eligible recipient of payment out of RRIF 267

26 September 2014 Internal T.I. 2014-0525241I7 - 60(l) - Financial Dependence Ward of the Crown

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30 May 1995 T.I. 950554 (C.T.O. "Possibility of Two 'Spouses'")

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21 September 1994 T.I. 941921 (C.T.O. "Refund of Premiums to Spouse")

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10 March 1992 T.I. (Tax Window, No. 17, p. 7, ¶1795)

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6 March 1990 T.I. (August 1990 Access Letter, ¶1385)

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6 February 1990 T.I. (July 1990 Access Letter, ¶1336)

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ATR-37 (4 Nov. 88)

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Retirement Income

Administrative Policy

14 June 1995 T.I. 950829 (C.T.O. "Beneficiary Named on Annuity")

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Retirement Savings Plan

See Also

Amherst Crane Rentals Ltd. v. Perring, 2004 DTC 6584 (Ont. CA)

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In Re Guterres, 94 DTC 6603 (FCTD)

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MNR v. Sinclair, 93 DTC 5239 (FCTD)

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Capital City Savings & Credit Union Ltd. v. 299474 Alberta Ltd., [1990] 3 WWR 763 (Alta. Q.B.)

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DeConinck v. Royal Trust Corp. of Canada, [1989] 1 CTC 179 (N.B.C.A.)

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Tax Topics - Income Tax Act - Section 224 - Subsection 224(1) ineffective demand on RRSP trustee 90

National Bank of Canada v. Creative Touch Millworks Inc., [1989] 2 WWR 180 (Sask QB)

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Re Bliss (1984), 44 OR (2d) 129 (SCO)

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In re Gero, 79 DTC 5228, [1979] CTC 309 (FCTD)

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Administrative Policy

6 November 2014 External T.I. 2014-0528521E5 F - Payment of management fees by employer

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Words and Phrases
LIRA
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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) taxable benefit on employer payment of RRSP (including LIRA) and TFSA fund management fees but not those of DPSPs or SERPs 66

30 May 1995 T.I. 950551 (C.T.O. "RRSP Trust with more than One Annuitant")

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4 August 1994 T.I. 941699 (C.T.O. "Foreign Currency in Depository RRSP")

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17 February 1994 T.I. 940130 (H.A.A. 7255-1) (C.T.O. "Retirement Income and RRSP Owned by Two Annuitants")

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27 January 1994 T.I. H.A.A. 7255-1

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Articles

Teichman, "Creditor-Proofing Pension Assets", Taxation of Executive Compensation and Retirement, November 1993, p. 835.

Biro, "The Erosion of Life Insurance RRSP Immunity from Creditor's Claims", Estates and Trusts Journal, Volume 13, No. 2, p. 189.

McKee, "Debtor-Creditor Issues Affecting Annuity Contract", Estates and Trust Journal, Volume 12, No. 3, March 1993.

RRSP Deduction Limit

Administrative Policy

1 September 1994 External T.I. 5-942050 -

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Deduction Limits

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Spousal Plan

Administrative Policy

14 July 1994 T.I. 941591 (C.T.O. "RRSP as Spousal Plan")

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Paragraph 146(1)(i.1)

Administrative Policy

3 February 1992 External T.I. 5-912583 -

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29 October 1991 T.I. (Tax Window, No. 12, p. 16, ¶1558)

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Subsection 146(2) - Acceptance of plan for registration

Paragraph 146(2)(a)

Cases

Vancouver A & W Drive-Ins Ltd. v. United Food Services Ltd. (1981), 13 BLR 89 (BCSC)

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Administrative Policy

26 July 1989 T.I. (Dec. 89 Access Letter, ¶1057)

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Paragraph 146(2)(c)

Administrative Policy

13 July 1994 T.I. 941543 (C.T.O. "Bankruptcy Trustee Seizing Registered Plan Assets")

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Paragraph 146(2)(c.3)

Cases

The Queen v. The Maritime Life Assurance Co., 2000 DTC 6402 (FCA)

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Tax Topics - Excise Tax Act - Section 131 73

In re the Bankruptcy of Whaling, 99 DTC 5478 (Ont CA)

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In Re Leavitt, 98 D.T.C 6282 (BCCA)

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Deloitte, Haskins & Sells Ltd, Trustee of Pheonix v. Bank of Nova Scotia, 89 DTC 5355 (Sask. C.A.)

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Articles

Boyd, "RRSP Loans: Re: Leavitt End Restrictions on Lenders' Rights Against the Plan", RRSP Planning, Vol. IV, No. 2, 1997, p. 249.

Paragraph 146(2)(c.4)

Administrative Policy

9 January 1997 T.I.

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2 November 1994 Memorandum 942733 (C.T.O. "RRSP Advantages of Low-Interest Loan")

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1 September 1992 T.I. (Tax Window, No. 24, p. 19, ¶2192)

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31 July 1991 T.I. (Tax Window, No. 7, p. 21, ¶1379)

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Subsection 146(4) - No tax while trust governed by plan

Administrative Policy

10 October 2014 APFF Roundtable, 2014-0538221C6 F - Day Trading in RRSP

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27 October 1994 T.I. 942710 (C.T.O. "Options as RRSP Qualified Investments")

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27 July 1994 T.I. 941656 (C.T.O. "RRSP Entering into a Spread with Options")

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19 May 1993 T.I. (Tax Window, No. 31, p. 5, ¶2512)

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22 February 1991 T.I. (Tax Window, Prelim. No. 3, p. 22, ¶1118)

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19 April 1990 T.I. (September 1990 Access Letter, ¶1431)

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Paragraph 146(4)(a)

Administrative Policy

S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs and TFSAs

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 204 - qualified investment - (a) 208
Tax Topics - Income Tax Act - Section 262 113
Tax Topics - Income Tax Act - Section 204 - qualified investment - (d) 320
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(b) 256
Tax Topics - Income Tax Act - Section 204.4 - Subsection 204.4(1) 107
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(2) 52
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j) 149
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j.1) 53
Tax Topics - Income Tax Act - Section 204 - qualified investment - (b) 55
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(e) 173
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (b) 69
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(u) 80
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(v) 50
Tax Topics - Income Tax Regulations - Regulation 4901 - Subsection (1) - Specified small business corporation 38
Tax Topics - Income Tax Regulations - Regulation 5100 - Eligible Corporation 44
Tax Topics - Income Tax Act - Section 207.04 - Subsection 207.04(4) 82
Tax Topics - Income Tax Act - Section 146 - Subsection 146(10.1) 90
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(6) 110
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(b) 94
Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(6) 156

Paragraph 146(4)(b)

Administrative Policy

S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs and TFSAs

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 204 - qualified investment - (a) 208
Tax Topics - Income Tax Act - Section 262 113
Tax Topics - Income Tax Act - Section 204 - qualified investment - (d) 320
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(b) 256
Tax Topics - Income Tax Act - Section 204.4 - Subsection 204.4(1) 107
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(2) 52
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j) 149
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j.1) 53
Tax Topics - Income Tax Act - Section 204 - qualified investment - (b) 55
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(e) 173
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (b) 69
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(u) 80
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(v) 50
Tax Topics - Income Tax Regulations - Regulation 4901 - Subsection (1) - Specified small business corporation 38
Tax Topics - Income Tax Regulations - Regulation 5100 - Eligible Corporation 44
Tax Topics - Income Tax Act - Section 207.04 - Subsection 207.04(4) 82
Tax Topics - Income Tax Act - Section 146 - Subsection 146(10.1) 90
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(6) 110
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(a) 118
Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(6) 156

Subsection 146(5) - Amount of RRSP premiums deductible

Administrative Policy

23 January 1997 T.I. 963958

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Tax Topics - Income Tax Act - Section 146.3 - Subsection 146.3(11) 25

8 June 1995 External T.I. 5-950732 -

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28 April 1995 T.I. 950344 (C.T.O. "Stock Option in RRSP")

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13 June 1994 T.I. 941241 (C.T.O. "Payment of RRSP/RESP Investment Expense")

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8 December 1993 T.I. 932271 (C.T.O. "Deduction of RRSP Overcontribution")

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8 May 1991 T.I. (Tax Window, No. 3, p. 30, ¶1247)

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May 1991 T.I. (C.T.O. Fax Service Document No. 96)

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22 September 1989 T.I. 5-8449 (C.T.O.)

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IT-320R2 "Registered Retirement Savings Plans - Qualified Investments"

IT-124R5 "Contributions to Registered Retirement Savings Plans"

Articles

Kaplan, "Registered Retirement Savings Plan: An Update", 1997 Canadian Tax Journal, Vol. 45, No. 6, p. 1416.

Ripsman:, "IPP, IPP, 'ooray", August 1993 CA Magazine, p. 39

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Boulanger, "Registered Retirement Savings Plan May Provide Greater Tax-Assisted Accumulation Under Certain Circumstances", Taxation of Executive Compensation and Retirement, October 1990, p. 339.

Subsection 146(5.1) - Amount of spousal RRSP premiums deductible

Administrative Policy

4 January 1992 T.I. (Tax Window, No. 28, p. 23, ¶2394)

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IT-307R2 "Registered Retirement Savings Plan for Taxpayer's Spouse"

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Tax Topics - Income Tax Act - Section 60 - Paragraph 60(j.1) 29

Subsection 146(5.21) - Anti-avoidance

Paragraph 146(5.21)(a)

Administrative Policy

20 December 1989 T.I. (May 1990 Access Letter, ¶1233)

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Subsection 146(6)

Cases

The Queen v. Chambers, 96 DTC 6095 (FCTD)

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See Also

Foreman v. MNR, 93 DTC 7 (TCC)

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition debt disposition includes its extinguishment 67

Paragraph 146(4)(a)

Administrative Policy

22 October 2015 Internal T.I. 2013-0486491I7 - Overdrafts in a TFSA

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Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(2) - Paragraph 146.2(2)(f) administrative accommodation of short term inadvertent overdrafts but not of cashless warrant exercise 340
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Unused contribution room deemed proceeds under s. 146.2(8) are not a distribution 139

Subsection 146(8) - Benefits taxable

Cases

Lavoie v. The Queen, 2009 DTC 998, 2009 TCC 293 (Informal Procedure), aff'd 2010 DTC 5171 [at 7303], 2010 FCA 266

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See Also

Demers v. The Queen, 2014 TCC 368

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Rectification & Rescission Superior Court nullification of investment contracts did not nullify RRSP withdrawals 167

Astorino v. The Queen, 2010 DTC 1112 [at 3061], 2010 TCC 144 (Informal Procedure)

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Israel v. The Queen, 79 DTC 5418, [1979] CTC 468 (FCTD)

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Administrative Policy

3 October 1996 T.I. 962856 (C.T.O. "RRSP Administration & Investment Management Fees")

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9 January 1996 T.I. 952868 (C.T.O. "Registered Retirement Savings Plan Issuer Interpleads to the Courts")

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4 July 1995 External T.I. 5-951695 -

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2 June 1995 T.I. 950375 ("Charitable Gift Annuity in RRSP")

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 27

30 November 1992 T.I. 923168 (September 1993 Access Letter, p.423, ¶C144-238)

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Subsection 146(8.1) - Deemed receipt of refund of premiums

Administrative Policy

11 October 2013 Roundtable, 2013-0495281C6 F - Question 9 - APFF Round Table

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(l) transfer to RRSP or RRIF of surviving non-resident spouse: SIN required; payment can be made directly to RRSP/RRIF of surviving spouse in accordance with joint instructions even where no specific non-will designation is made 510
Tax Topics - Income Tax Act - Section 146.3 - Subsection 146.3(6.1) transfer of RRIF by executor to RRIF of surviving spouse 306
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - lParagraph 212(1)(q) direct transfer to RRIF of surviving non-resident spouse 280

2 May 1995 T.I. 942676 (C.T.O. "RRSP's RRIF's, 212(1)")

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20 November 1991 Memorandum (Tax Window, No. 7, p. 7, ¶1390)

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10 April 1991 T.I. (Tax Window, No. 2, p. 26, ¶1198)

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Subsection 146(8.2)

Administrative Policy

23 October 2017 External T.I. 2017-0685001E5 F - Withdrawal of RRSP over-contributions after death

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6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 4, 2017-0707781C6 F - Withdrawal of undeducted RRSP contributions

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6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 2, 2017-0710681C6 F - Withdrawal of RRSP over-contributions after death

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Tax Topics - Income Tax Act - Section 146 - Subsection 146(8.8) income inclusion under s. 146(8.8) on death irrespective whether premiums exceeded deductible amount 108

Subsection 146(8.3) - Spousal or common-law partner payments

Cases

Gilbert v. The Queen, 93 DTC 5115 (FCA)

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Administrative Policy

18 September 2013 External T.I. 2012-0462061E5 F - Amount included in the income of the annuitant

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Subsection 146(8.8) - Effect of death where person other than spouse becomes entitled

Cases

Curley v. MacDonald, 2001 DTC 5141 (Ont Sup CT J)

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Slater v. Klassen Estate, 2000 DTC 6336 (Man. Q.B.)

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See Also

Murphy Estate v. The Queen, 2015 TCC 8

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Tax Topics - General Concepts - Effective Date disclaimer has retroactive effect 120

Administrative Policy

6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 2, 2017-0710681C6 F - Withdrawal of RRSP over-contributions after death

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Tax Topics - Income Tax Act - Section 146 - Subsection 146(8.2) deemed s. 146(8.8) benefit on death treated as RRSP withdrawal, and executor should not use Form T746 215

14 October 1997 T.I. 970653

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Tax Topics - General Concepts - Fair Market Value - Shares 64

19 August 1993 T.I. (Tax Window, No. 33, p.8, ¶2644)

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1992 A.P.F.F. Annual Conference, Q. 20 (January - February 1993 Access Letter, p. 58)

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Subsection 146(8.9) - Idem [Effect of death where person other than spouse becomes entitled]

Administrative Policy

9 January 1996 T.I. 951718 (C.T.O. "Death, Registered Retirement Savings Plan Maturity, Spouse")

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16 July 1991 T.I. (Tax Window, No. 6, p. 9, ¶1353)

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Subsection 146(8.91) - Amounts deemed receivable by spouse or common-law partner

Administrative Policy

4 March 1991 T.I. (Tax Window, No. 1, p. 12, ¶1132)

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Subsection 146(9) - Where disposition of property by trust

Cases

St. Arnaud v. Canada, 2013 DTC 5074 [at 5909], 2013 FCA 88

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See Also

Baker v. The Queen, 2014 DTC 1175 [at 3649], 2014 TCC 204

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Administrative Policy

28 April 1995 T.I. 950108 (C.T.O. "Transfer of RRSP Funds to Charity Issued Annuity")

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30 January 1995 T.I. 943068 (C.T.O. "RRSP Qualified Investments - Puts & Calls")

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27 October 1994 T.I. 942710 (C.T.O. "Options as RRSP Qualified Investments")

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19 May 1993 T.I. (Tax Window, No. 31, p. 5, ¶2512)

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10 July 1992 External T.I. 5-921881 -

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Articles

Singer, "RRSPs Can Invest in a Wide Range of Equities", Taxation of Executive Compensation and Retirement, April 1990, p. 259

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Subsection 146(10) - Property used as security for loan

Cases

Caisse populaire Desjardins de Val-Brillant v. Blouin, 2003 DTC 5420, 2003 SCC 31, [2003] 1 S.C.R. 666

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Provincial Law 76

See Also

Lavoie v. The Queen, 2009 DTC 998, 2009 TCC 293 (Informal Procedure), aff'd 2010 DTC 5171 [at 7303], 2010 FCA 266

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Dubuc c. La Reine, 2005 DTC 461, 2004 TCC 164 (Informal Procedure)

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Administrative Policy

7 January 2003 External T.I. 2002-015137 -

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11 October 2000 External T.I. 2000-004025 -

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8 June 1999 External T.I. 5-990650 -

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30 January 1995 T.I. 943068 (C.T.O. "RRSP Qualified Investments - Puts & Calls")

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23 March 1994 T.I. 940596 (C.T.O. "Mortgage in RRSP")

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1 June 1993 External T.I. 5-930642 -

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19 May 1993 T.I. (Tax Window, No. 31, p. 5, ¶2512)

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27 June 1991 T.I. (Tax Window, No. 4, p. 30, ¶1319)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.1 - Subsection 207.1(1) 51

Articles

Singer, "Mortgages with Equity Tickers May Qualify as RRSP Investment", Taxation of Executive Compensation and Retirement, May 1990, p. 283.

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Subsection 146(10.1) - Where tax payable

Administrative Policy

S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs and TFSAs

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 204 - qualified investment - (a) 208
Tax Topics - Income Tax Act - Section 262 113
Tax Topics - Income Tax Act - Section 204 - qualified investment - (d) 320
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(b) 256
Tax Topics - Income Tax Act - Section 204.4 - Subsection 204.4(1) 107
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(2) 52
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j) 149
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j.1) 53
Tax Topics - Income Tax Act - Section 204 - qualified investment - (b) 55
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(e) 173
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (b) 69
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(u) 80
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(v) 50
Tax Topics - Income Tax Regulations - Regulation 4901 - Subsection (1) - Specified small business corporation 38
Tax Topics - Income Tax Regulations - Regulation 5100 - Eligible Corporation 44
Tax Topics - Income Tax Act - Section 207.04 - Subsection 207.04(4) 82
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(6) 110
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(a) 118
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(b) 94
Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(6) 156

4 December 2014 External T.I. 2014-0529681E5 - Non-qualified investments acquired by RRSP Trust

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Tax Topics - Income Tax Act - Section 207.04 - Subsection 207.04(2) non-qualified stock dividend on qualified or non-qualified shares 222

12 July 2013 External T.I. 2012-0447191E5 - RRSP trust taxation under 146(10.1)

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Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(6) gain due to ACB grind 77

Subsection 146(16) - Transfer of funds

Administrative Policy

7 October 2016 APFF Financial Strategies and Financial Instruments Roundtable Q. 5, 2016-0651721C6 F - Application of subsections 146(16) and 73(1) after death

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Tax Topics - Income Tax Act - Section 73 - Subsection 73(1.01) - Paragraph 73(1.01)(b) no rollover if transferor spouse dies before transfer pursuant to separation agreement made 142

30 January 1990 T.I. (June 1990 Access Letter, ¶1276)

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Paragraph 146(16)(b)

Administrative Policy

6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 1, 2017-0705221C6 F - Property transfers - common law partners in Québec

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 73 - Subsection 73(1.01) - Paragraph 73(1.01)(b) rollover under common-law partners' separation agreement irrespective of whether technically they have separation rights to settle 138
Tax Topics - Income Tax Act - Section 146.3 - Subsection 146.3(14) rollover pursuant to common-law partners' settlement agreement 96