Section 207.01

Subsection 207.01(1) - Definitions

Advantage

Administrative Policy

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

CRA indicated that each of the following payments made to a TFSA would not, in and of itself, constitute an advantage:

  • The TFSA holder uses a...

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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)(c) remuneration or a trust distribution paid directly to a TFSA is not a 3rd-party contribution 135

28 May 2015 External T.I. 2015-0574481E5 - Advantage tax and employee-owned securities

Have the views expressed in 2009-0320311I7 and 2009-0323391R3 changed in light of the amendment to s. (b)(i) of the definition of "advantage" that...

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May 2013 ICAA Roundtable, Q. 10 (reported in April 2014 Member Advisory)

What criteria apply in determining whether a transaction or event or a series of transactions or events involving a TFSA would not have occurred...

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28 May 2014 External T.I. 2013-0486111E5 F - RRSP, prohibited investment

The shares of an RRSP, which were prohibited investments held by it on 23 March 2011 and for which it made the transitional benefit election in s....

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(13) s. 51 exchange of transitional prohibited property does not trigger s. 207.04(1) tax 134
Tax Topics - Income Tax Act - Section 207.05 - Subsection 207.05(4) s. 207.05(4) status is preserved following s. 51 exchange 120

6 June 2013 External T.I. 2012-0451801E5 F - deemed dividend, advantage

An RRSP which holds shares which became a prohibited investment on March 22, 2011, and which subsequently did not appreciate in value,...

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ITTN No. 44 under "Key Employee Tax-Free Savings Account," 14 April 2011

After confirming the proposition posed that "where common shares of a company are issued to a tax-free savings account (TFSA) of a key employee as...

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Articles

Maureen De Lisser, Janna Krieger, "Registered Savings Plans: Investing Without Penalty", Canadian Tax Journal, (2013) 61:3, 769-96.

Illustration of value shift from RRSP to TFSA (pp. 784-5)

The following example illustrates a swap transaction and an RRSP strip that these rules...

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Paragraph (a)

Administrative Policy

S3-F10-C3 - Advantages – RRSPs, RESPs, RRIFs, RDSPs, and TFSAs

3.6 “Where a benefit or debt is connected in any way with the existence of a plan, it is considered to be conditional on the existence of...

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1 June 2016 External T.I. 2015-0601211E5 - Mortgage loan from RRSP to make a shareholder loan

An individual, who is an RRSP annuitant, borrows the “Mortgage Loan” from the RRSP, with a principal residence mortgage granted in favour of...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) money borrowed by individual from RRSP to make interest-free loan to corporation 181
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j.1) use of qualified mortgage loan proceeds of no import 184
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Registered Plan Strip 4900(1)(j.1) mortgage loan unlikely to be acquired at less than FMV 225

27 January 2014 External T.I. 2013-0504191E5 F - RRSP, qualified investment

An RRSP annuitant uses, for no consideration, property of a corporation of which the RRSP holds shares. Is this an advantage? CRA responded...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 4901 - Subsection 4901(2) - Specified Small Business Corporation general discussion of SSBC definition 235

Subparagraph (a)(i)

Subparagraph (a)(ii)

Administrative Policy

Subparagraph (a)(v)

Administrative Policy

3 April 2020 External T.I. 2019-0830101E5 - “Advantage”: promotional incentive exception

Q.1 and Q.2

S. (a)(v) of the advantage definition, as paraphrased by CRA in Folio S3-F10-C3, excludes “a promotional incentive under a program...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(1) - Premium referral bonus is considered to be a premium contributed to the plan 173

Paragraph (b)

Administrative Policy

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

Advantage tax

1.44 The advantage tax in section 207.05 could apply if an RRSP, RRIF or TFSA trust were to engage in certain option transactions....

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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 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

7 November 2012 External T.I. 2012-0437821E5 F - Registered Plan - Advantage

Would the transfer of an individual’s shares of a credit union to the individual’s RRIF, RRSP or TFSA ("registered plan") comes within the...

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14 February 2012 External T.I. 2011-0416621E5 F - REER, swap

Respecting a proposed swap of a savings bond held in an RRSP and a savings bond held in a non-registered account, before concluding that it was...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - RRSP Strip swap of savings bond between RRSP and non-registered account would be an RRSP strip 80

Subparagraph (b)(i)

Cases

Louie v. Canada, 2019 FCA 255

From May 15 to October 17, 2009, the taxpayer directed 71 “swaps” under which TSX-listed shares were transferred between her self-directed...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.06 - Subsection 207.06(2) concerns about future value increases are intended to be addressed by relief provisions 384
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) no necessity for predetermined endpoint or advance determination of price 211
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) taxpayer was directing mind in transactions involving an arm’s length trustee 137

See Also

Louie v. The Queen, 2018 TCC 225, rev'd in part on "advantage" issue (for subsequent years) 2019 FCA 255

From May 15 to October 17, 2009, the taxpayer directed 71 “swaps” under which TSX-listed shares were transferred between her self-directed...

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Words and Phrases
directly or indirectly
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) share swap transactions were series notwithstanding that their particulars and end point were not known in advance 189
Tax Topics - Income Tax Act - Section 207.05 - Subsection 207.05(3) holder rather than trustee liable for advantage tax 148
Tax Topics - General Concepts - Fair Market Value - Shares use of price range for share valuation was inappropriate where there was a second-by-second market 185

Administrative Policy

27 November 2018 CTF Roundtable Q. 12, 2018-0785021C6 - Investment management fees

CRA stated:

The Department of Finance Canada advised us earlier this year that they will be reviewing the issue from a tax policy perspective. As...

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28 September 2018 External T.I. 2018-0779261E5 - Investment management fees

In 29 November 2016 CTF Roundtable Q. 5, 2016-0670801C6, CRA indicated that it now considered the payment of fees for investment management of an...

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15 September 2017 External T.I. 2017-0722391E5 - Investment management fees

In 29 November 2016 CTF Roundtable Q. 5, 2016-0670801C6, CRA indicated that the payment of fees for investment management of an RRSP, RRIF or TFSA...

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29 November 2016 CTF Roundtable Q. 5, 2016-0670801C6 - Investment management fees

CRA considers that the payment of fees for investment management of an RRSP, RRIF or TFSA by the plan annuitant or holder typically will be...

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Finance

26 August 2019 Comfort Letter - “Advantage”: Exclusion for Investment Management Fees

[If] investment management fees of registered plans … are paid directly by the holder/annuitant using funds outside of the plan, the resulting...

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Subparagraph (b)(ii)

Administrative Policy

27 May 2009 Internal T.I. 2009-0320311I7 F - CELI - Notion d'avantage

The sole shareholder (Mr. X) of Opco engages in a freeze transaction as a result of which he holds all the preferred shares and 95% of the common...

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Subparagraph (b)(iii)

Administrative Policy

Paragraph (c)

Administrative Policy

17 April 2013 External T.I. 2012-0457011E5 F - Coop Shares in RRSP and Prohibited Invest. Rules

The correspondent expressed concern that although the new rules effectively required an RRSP holding shares of a cooperative to dispose of some of...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Excluded Property - Paragraph (c) shares can become prohibited investments as a result of other shareholders dispose of their shares 373
Tax Topics - Income Tax Act - Section 207.04 - Subsection 207.04(4) dispositions that generate the refund are not limited to redemptions of the shares 226

Deliberate Over-Contribution

Administrative Policy

14 July 2020 External T.I. 2020-0843071E5 - TFSA - Deliberate Over-contributions

In response to an inquiry as to the consequences to an individual who intentionally makes a TFSA contribution in excess of the available...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.02 no requirement to distribute income on a TFSA overcontribution where there has been 1% monthly tax but no advantage tax 45

Excluded Property

Paragraph (c)

Administrative Policy

17 April 2013 External T.I. 2012-0457011E5 F - Coop Shares in RRSP and Prohibited Invest. Rules

In the course of a general discussion of the application of the prohibited investment rules to an RRSP that held shares of a cooperative on March...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.04 - Subsection 207.04(4) dispositions that generate the refund are not limited to redemptions of the shares 226
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (c) advantage tax on net capital gains and income of RRSP from cooperative shares 352

S3-F10-C2 - Prohibited Investments – RRSPs, RRIFs and TFSAs

Meaning of "regarding the governance"

2.18 ... One of the conditions [in "excluded property" - (c)(iii)] sets limits regarding the governance of...

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26 November 2014 External T.I. 2014-0545041E5 - Registered plans - Excluded property

The annuitant of an RRSP or RRIF or the holder of a TFSA owns 2% of the shares (being common shares only) of a corporation and together with the...

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Exempt Contribution

Paragraph (b)

Administrative Policy

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 5, 2020-0851601C6 F - TFSA Exempt Contribution - Spousal Trust

Mr. X’s TFSA formed part of the residue of his estate which, as such, was bequeathed by the terms of his will to a spousal trust, with a lump...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(a) indirect transfer made in accordance with deceased’s will would be as a consequence of death 235

11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 7, 2019-0821701C6 F - TFSA Exempt Contribution - Survivor payment

Mr. X, who died on January 1, 2018, made a specific bequest of his TFSA to his surviving spouse (Ms. Y). However, the estate administration...

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11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 6, 2019-0813451C6 F - TFSA - Bequest and disclaimer

Although Mr. X made a specific bequest of his TFSA to his adult daughter, she executed a written renunciation of the bequest (that CRA went on to...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(b) transfer of TFSA to survivor on renunciation of bequest thereof occurred as a consequence of death 139

11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 4, 2019-0813421C6 F - TFSA - Survivor Payment - Decrease in FMV

Situation 1

Mr. X made a specific bequest of his TFSA to his spouse (Ms. Y), which had declined in value from $100,000 to $90,000 between death...

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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 - Paragraph (b) - Element D diminution in TFSA property in executors' hands reduces exempt contribution 216

6 June 2017 External T.I. 2015-0617331E5 F - TFSA - Exempt Contribution

Would the transfer of a TFSA to the deceased's spouse as a total or partial payment of a debt owed to the spouse under the partition of the family...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(23.1) - Paragraph 248(23.1)(a) payment of family-law obligation of deceased to surviving spouse out of deceased's TFSA could qualify 84
Tax Topics - Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(a) legacy of residue (which included the residence) could be satisfied with TFSA of deceased 101

11 May 2017 External T.I. 2016-0679751E5 F - TFSA - Exempt Contribution

Would a transfer of funds from a deceased holder's TFSA to the holder's surviving spouse in order to pay a specific legacy satisfy para. (b) of...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(a) legacy made by executor exercising discretion conferred under will occurred because of death 78

Paragraph (c)

Administrative Policy

11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 5, 2019-0820901C6 F - TFSA Exempt Contribution - Timing of contribution

Mr. X, who died on January 1, 2018, had made a specific bequest of his TFSA (valued at death at $100,000) to his spouse (Ms. Y), who contributed...

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Paragraph (d)

Subparagraph (d)(iii)

Administrative Policy

5 October 2012 Roundtable, 2012-0453171C6 F - TFSA - Survivor payments to more than one survivor

In Situation 1, on the death of Mr. X, his will directed the $20,000 in his TFSA held with a Canadian financial institution to be paid as to...

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8 October 2010 Roundtable, 2010-0371961C6 F - Époux et conjoint de fait et CÉLI au décès

The deceased individual provided for the splitting of his TFSA equally between his wife (from whom he lived separate and apart) and his common-law...

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Prohibited Investment

Administrative Policy

18 February 2009 External T.I. 2008-0304051E5 - TFSA - Mutual Fund being a Prohibited Investment

Mutual fund trusts will be considered to be prohibited investments if the holder of the TFSA, either alone or with other non-arm's length parties,...

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Articles

Todd Miller, Michael Friedman, Carl Irvine, "The New RRSP/RRIF Anti-Avoidance Regime: A Roadmap and Tips for the Unwary", Taxation of Executive Compensation and Retirement, Vol. 23, No. 4, p. 1463

In light of the breadth of "significant interest" (p.1465):

It is possible that an individual could unknowingly hold a "significant interest" in...

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Paragraph (b)

Subparagraph (b)(i)

Administrative Policy

22 November 2012 External T.I. 2012-0441781E5 F - Prohibited Investment - Cooperative

Before concluding that an investment in a cooperative could be a prohibited investment because of s. 207.01(1)(b)(i) of “prohibited...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(15) application to shares of cooperative 115
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder investor in cooperative holds shares and is shareholder 181

Registered Plan Strip

Administrative Policy

25 February 2021 Internal T.I. 2020-0865641I7 - Settlement Payments to Registered Plans

After noting that it is CRA’s policy to consider that a settlement payment made to an RRSP or RRIF respecting an actionable loss suffered by it...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(8) damages payment received by annuitant is not a benefit if paid over to the RRSP by year end 253
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Unused TFSA Contribution Room - Paragraph (b) - Element D damages payments made to a TFSA are not treated as a contribution 143
Tax Topics - Income Tax Act - Section 146.4 - Subsection 146.4(6) RDSP damages paid to and retained by the beneficiary would be taxable 220
Tax Topics - Income Tax Act - Section 146.1 - Subsection 146.1(7.1) RESP damages received and retained by the subscriber would be included under s. 146.1(7.1) 174

S3-F10-C3 - Advantages – RRSPs, RESPs, RRIFs, RDSPs, and TFSAs

Definition can apply even where no property removal

3.34 The definition [of registered plan strip] is intended to apply even in situations...

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1 June 2016 External T.I. 2015-0601211E5 - Mortgage loan from RRSP to make a shareholder loan

An individual, who is an RRSP annuitant, borrows the “Mortgage Loan” from the RRSP, with a principal residence mortgage granted in favour of...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) money borrowed by individual from RRSP to make interest-free loan to corporation 181
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j.1) use of qualified mortgage loan proceeds of no import 184
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (a) 4900(1)(j.1) insurance requirements generally arm's length/potential advantage on default 247

16 October 2012 External T.I. 2012-0439151E5 - RRSP strips and prohibited investments

Respecting an expressed concern that the sale of a prohibited investment by an RRSP or RRIF to the annuitant for fair market value consideration...

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RRSP Strip

Administrative Policy

14 February 2012 External T.I. 2011-0416621E5 F - REER, swap

Respecting a proposed swap of a savings bond held in an RRSP and a savings bond held in a non-registered account, before concluding that it was...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (b) computation of advantage from swap transaction 257

Swap Transaction

Administrative Policy

S3-F10-C3 - Advantages – RRSPs, RESPs, RRIFs, RDSPs, and TFSAs

Permitted exceptions

3.25 Contributions, distributions to the plan’s controlling individual, and purchase and sale transactions between an...

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12 December 2012 External T.I. 2012-0460611E5 - swap of securities between registered plans

[C]ontributions, distributions, and purchase and sale transactions between an individual's two plans with the same tax attributes (i.e., TFSA to...

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24 August 2010 External T.I. 2010-0359001E5 - TFSA - Swap Transaction

Can an individual contribute a non-maturing GIC into his or her TFSA? CRA responded:

A "swap transaction", in relation to a TFSA trust,...

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Unused TFSA Contribution Room

Administrative Policy

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

Where a trust ceases to be a TFSA pursuant to s. 146.2(5)(c), so that s. 146.2(8) deems the trust to have disposed of all its properties at fair...

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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)(f) administrative accommodation of short term inadvertent overdrafts but not of cashless warrant exercise 372
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

22 November 2012 External T.I. 2012-0468941E5 F - TFSA - XXXXXXXXXX employee working outside Canada

Can someone working outside Canada open a self-directed tax-free savings account (“TFSA”)? After noting that an individual’s residence is a...

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Paragraph (b)

Element D

Administrative Policy

25 February 2021 Internal T.I. 2020-0865641I7 - Settlement Payments to Registered Plans

After noting that it is CRA’s policy to consider that a settlement payment made to an RRSP or RRIF respecting an actionable loss suffered by it...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(8) damages payment received by annuitant is not a benefit if paid over to the RRSP by year end 253
Tax Topics - Income Tax Act - Section 146.4 - Subsection 146.4(6) RDSP damages paid to and retained by the beneficiary would be taxable 220
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Registered Plan Strip advantage if RDSP damages are received by a holder who is not a beneficiary 220
Tax Topics - Income Tax Act - Section 146.1 - Subsection 146.1(7.1) RESP damages received and retained by the subscriber would be included under s. 146.1(7.1) 174

11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 4, 2019-0813421C6 F - TFSA - Survivor Payment - Decrease in FMV

The definition of “exempt contribution” in s. 207.01(1) contemplates that the “survivor” of an individual can make a contribution on an...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Exempt Contribution - Paragraph (b) survivor payment equals amounts paid under the TFSA to the estate provided the survivor receives at least that amount as TFSA beneficiary 312

Subsection 207.01(4)

Administrative Policy

Paragraph 207.01(4)(a)

Administrative Policy

20 March 2015 External T.I. 2014-0528311E5 - Mortgage Investment Corporation - RRSP

Would a specified shareholder of a mortgage investment corporation include a brother or sister of the RRSP annuitant? After noting that a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 130.1 - Subsection 130.1(6) shareholdings of siblings not included 61

Subsection 207.01(6)

Administrative Policy

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

Effect of deemed FMV disposition

1.77 Subsection 207.01(6) provides a special rule that applies when an investment becomes or ceases to be a...

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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 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

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

An RRSP acquired shares after March 23, 2011, which were listed on a foreign designated stock exchange and were worth $43 per share, but then...

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Tax Topics - Income Tax Act - Section 146 - Subsection 146(10.1) gain due to ACB grind 81

Subsection 207.01(13)

Administrative Policy

28 May 2014 External T.I. 2013-0486111E5 F - RRSP, prohibited investment

The shares of an RRSP, which were prohibited investments held by it on 23 March 2011 and for which it made the transitional benefit election in s....

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Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage no advantage on s. 51 exchange 89
Tax Topics - Income Tax Act - Section 207.05 - Subsection 207.05(4) s. 207.05(4) status is preserved following s. 51 exchange 120