Section 146.2

Old Paragraph 146.2(1)(c)

See Also

Dep. MNR v. Bonair Leisure Industries Ltd., 82 DTC 6217, [1982] CTC 188 (FCA)

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Subsection 146.2(2) - Qualifying arrangement conditions

Paragraph 146.2(2)(a)

Administrative Policy

22 January 2018 Internal T.I. 2017-0727421I7 - Whether a TFSA account may be subject to setoff

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(4) most express rights of set-off put the TFSA offside 201

27 June 2017 External T.I. 2017-0708951E5 F - TSFA - Conditions

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(4) (apparently permitted) covenant in TFSA declaration requiring asset minimum to support loan to holder 169

Paragraph 146.2(2)(c)

Administrative Policy

20 August 2018 External T.I. 2017-0731541E5 - TFSA contributions

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20 August 2018 External T.I. 2018-0739761E5 - TFSA contributions

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage the payment of remuneration or a trust distribution directly to a TFSA is not an advantage 121

Paragraph 146.2(2)(e)

Administrative Policy

14 May 2019 CLHIA Roundtable Q. 7, 2019-0799121C6 - 2019 CLHIA Conference Roundtable Question 7

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Articles

Max Reed, "TFSA: US Tax Classification", Canadian Tax Highlights, Vol. 22, No. 7, July 214, p. 5

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Paragraph 146.2(2)(f)

Administrative Policy

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

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Unused TFSA Contribution Room deemed proceeds under s. 146.2(8) are not a distribution 147
Tax Topics - Income Tax Act - Section 146 - Subsection 146(6) - Paragraph 146(4)(a) accommodation only of temporary technical breach of borrowing prohibition for registered plans 238

Subsection 146.2(4)

Administrative Policy

22 January 2018 Internal T.I. 2017-0727421I7 - Whether a TFSA account may be subject to setoff

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(2) - Paragraph 146.2(2)(a) a set-off right of an issuer of a TFSA violated the exclusive holder benefit rule 147

27 June 2017 External T.I. 2017-0708951E5 F - TSFA - Conditions

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(2) - Paragraph 146.2(2)(a) negative covenant in favour of lender to TFSA holder permitted 57

28 August 2015 External T.I. 2013-0514261E5 - Using the Assets of a TFSA as Security for a Loan

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Subsection 146.2(5)

Paragraph 146.2(5)(c)

Administrative Policy

17 July 2019 Internal T.I. 2017-0718021I7 - Deregistration of TFSA

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) s. 75(2) applied to 1st generation but not 2nd generation income of a non-qualified purported TFSA trust 276

26 February 2015 External T.I. 2015-0569601E5 F - Contribution to a TFSA

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Subsection 146.2(6) - Trust not taxable

Administrative Policy

22 March 2018 Internal T.I. 2018-0738201I7 - Residency of TFSA trust

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) all self-directed RRSPs and TFSAs are resident in Canada 162

13 June 2017 STEP Roundtable Q. 13, 2017-0693341C6 - TFSA Audit Project

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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 - Paragraph (a) 296
Tax Topics - Income Tax Act - Section 262 133
Tax Topics - Income Tax Act - Section 204 - Qualified Investment - Paragraph (d) 388
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(b) 294
Tax Topics - Income Tax Act - Section 204.4 - Subsection 204.4(1) 172
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(2) 64
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j) 167
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j.1) 75
Tax Topics - Income Tax Act - Section 204 - Qualified Investment - Paragraph (b) 65
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(e) 217
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (b) 85
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(u) 92
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(v) 60
Tax Topics - Income Tax Regulations - Regulation 4901 - Subsection 4901(2) - Specified Small Business Corporation 64
Tax Topics - Income Tax Regulations - Regulation 5100 - Eligible Corporation 54
Tax Topics - Income Tax Act - Section 207.04 - Subsection 207.04(4) 92
Tax Topics - Income Tax Act - Section 146 - Subsection 146(10.1) 100
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(6) 128
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(a) 138
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(b) 104

18 January 2010 External T.I. 2009-0340431E5 F - REER, exploitation d'une entreprise

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Articles

Arthur B.C. Drache, "TFSAs as a Business", The Canadian Taxpayer, January 2, 2015 – Vol. xxxvii No. 1, p. 5.

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