Section 204

Equity Share

Qualified Investment

Paragraph (a)

See Also

Air Canada v. Min. of Fin. for B.C., [1981] 2 WWR 97 (BCCA)

Certificates of deposit, bearer deposit notes, swap deposit confirmations and bankers' acceptances were held to be "loans and advances to other...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
cash on deposit deposit

Administrative Policy

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

Digital currency and FX contracts excluded

1.12 ... Digital currencies, such as Bitcoins, are not considered to be money issued by a government of...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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
Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(6) 196

4 May 2006 Roundtable, 2005-0161541C6 F - Placements admissibles - dépôts

As part of its response to the question as to whether a guaranteed investment certificate or term deposit denominated in Canadian or foreign...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 204 - Qualified Investment - Paragraph (b) GIC or term deposit is a similar obligation 94
Tax Topics - Income Tax Act - Section 204 - Qualified Investment - Paragraph (f) GIC could qualify under para. (b) or (f) 123

12 October 2001 Ministerial Correspondence 2001-0099384 - RRSP QUALIFIED INVESTMENT

Following the amendment retroactive to June 27, 1999 "taxpayers may now approach a financial institution and request that dividends paid in the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

27 July 1994 External T.I. 9416565 - RRSP ENTERING INTO A SPREAD WITH OPTIONS

Where an RRSP is required to leave cash on deposit with a broker to cover the possible exercise of a call option granted by the RRSP to the option...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) enetering into spread indicative of business 44

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

Cash on deposit by an RRSP with a broker to cover the possible exercise of a naked call option written by it would not be considered a qualified...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Articles

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

Where a deposit is negotiable or is not redeemable without capital penalty, it is regarded as a corporate obligation rather than as a deposit.

Related Provisions

Definition of Deposit per Canada Deposit Insurance Act and Schedule thereto (as at 2020/10)

Schedule

Definition of "deposit" 2. (1) Subject to...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Paragraph (b)

Administrative Policy

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

Undivided interests in strip coupons

1.37 ... Provided the original bond is a qualified investment, both the interest-paying portion and the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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 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
Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(6) 196

4 May 2006 Roundtable, 2005-0161541C6 F - Placements admissibles - dépôts

As part of its response to the question as to whether a guaranteed investment certificate or term deposit denominated in Canadian or foreign...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 204 - Qualified Investment - Paragraph (f) GIC could qualify under para. (b) or (f) 123
Tax Topics - Income Tax Act - Section 204 - Qualified Investment - Paragraph (a) not a qualifying deposit if payable outside Canada or in foreign currency 181

13 May 1994 External T.I. 9409805 - RRSP QUALIFIED INVESTMENT - CROWN CORPORATION

Bonds issued by provincial crown corporations are qualified investments.

Paragraph (c)

Administrative Policy

4 April 1991 T.I. (Tax Window, No. 2, p. 26, ¶1193)

A banker's acceptance is not a "similar obligation" because it is a bill of exchange and does not evidence indebtedness of the issuer.

Articles

David W. Glicksman, Kevin Kelly, "Linked Instruments Offer Investor Attractions", Corporate Finance, Vol. XII, No. 2, p. 1182.

Paragraph (c.1)

Administrative Policy

31 January 2013 External T.I. 2012-0444371E5 - Section 204-Qualified Investment-Paragraph (c.1)

A rating provided by an affiliate or subsidiary of a listed rating agency may be considered a rating provided by the listed rating agency. For...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Paragraph (d)

Administrative Policy

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

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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 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
Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(6) 196

27 March 2014 Ministerial Correspondence 2014-0518601M4 - Non-qualified investments held in registered plans

"In our view, the term "securities" should be given a broad application and interpreted using the ordinary meaning of the term."

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.04 - Subsection 207.04(2) tax triggered when qualified investment becomes non-qualified 108

15 January 2009 External T.I. 2008-0272681E5 F - Options d'achat sur devises

Regarding call and put options on currencies listed on the Montreal Exchange, CRA stated:

[S]ecurities, representing currency options listed on...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

4 November 1999 External T.I. 9924305 - FOREIGN STOCK EXCHANGE INDEX UNITS

Prior to the amendments announced by Finance on 18 December 1998, WEBS qualified as shares listed a prescribed foreign stock exchange, whereas...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

30 November 1996 Ruling 9716083 - AMERICAN DEPOSITARY SHARES, OPTIONS

American depositary shares would be considered to be shares for purposes of s. 7, as CRA previously had concluded that they were shares for...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

28 February 1992 T.I. (Tax Window, No. 17, p. 17, ¶1772)

Because the Canadian Over-the-Counter Automated Trading System is not a prescribed stock exchange in Canada, shares traded on this system would...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Read, "Technical Matters", 89 C.R. p. 783

A share that is "approved for listing" or that has a "conditional approval for listing" is not at that time listed on a prescribed stock exchange.

Paragraph (f)

Administrative Policy

4 May 2006 Roundtable, 2005-0161541C6 F - Placements admissibles - dépôts

As part of its response to the question as to whether a guaranteed investment certificate or term deposit denominated in Canadian or foreign...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 204 - Qualified Investment - Paragraph (b) GIC or term deposit is a similar obligation 94
Tax Topics - Income Tax Act - Section 204 - Qualified Investment - Paragraph (a) not a qualifying deposit if payable outside Canada or in foreign currency 181

Paragraph (h)

Administrative Policy

23 June 1995 External T.I. 9510135 - RRSP QUALIFIED INV US INDEX SECURITY

An American Depository Receipt is a qualified investment for an RRSP because the ADR represents ownership of the underlying shares and assuming...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

14 September 1994 External T.I. 9421855 - RRSP INVESTMENTS CEASE TRADE DELISTED HALTED SHARES

Where the only prescribed stock exchange on which a share is listed is outside Canada, a delisting of the share will generally cause the share to...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Articles

Allgood, Wilkie, "Pre-Release Mechanisms in American Depositary Receipt Arrangements Require Careful Review", Corporate Finance, 1992, Vol. I, No. 2, p. 28.