Subsection 207.1(1)
Cases
Thye RRSP of James T. Grenon (552-53721) by its Trustee CIBC Trust Corporation v. Canada, 2025 FCA 129
The Minister assessed Part XI.1 tax on the appellant RRSP (“Grenon RRSP”), which held non-qualified investments, computed at 1% of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 4801 | distribution of units to minors so as to fail to achieve the targeted minimum of qualified investors purchasing under an offering memorandum was not a lawful distribution | 670 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(3.1) | assessment of group RRSP return focused on Pt. XI.1 tax reporting did not start the Pt. I normal reassessment period running | 279 |
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 27 - Subsection 27(1.3) | FCA raised the correctness of (and reversed) a TCC finding that was not challenged by the parties | 420 |
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(10.1) | RRSP must recognize losses on non-qualified investments but such losses, if capital losses, cannot be deducted from property income from such investments | 153 |
| Tax Topics - Statutory Interpretation - Consistency | presumption that same word has same meaning, and different words have different meanings throughout the ITA | 233 |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | meaning of “distribution” informed by provincial securities law | 161 |
| Tax Topics - Statutory Interpretation - French and English Version | 2-step approach to reconciling 2 versions | 298 |
See Also
Grenon v. The Queen, 2021 TCC 30, aff'd in part 2025 FCA 129
In order that the taxpayer’s RRSP could indirectly invest in operating businesses in which he had a management role, he instigated the formation...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 4801 - Paragraph 4801(a) - Subparagraph 4801(a)(i) - Clause 4801(a)(i)(A) | distribution of units that included significant purchases by minors and by adults who did not pay for their own units, was unlawful | 756 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | purported establishment of “alter ego” MFTs through which an RRSP could invest in operating businesses was an abuse engaging GAAR | 605 |
| Tax Topics - Income Tax Act - Section 204.2 - Subsection 204.2(1.1) | alleged distribution from non-qualified investment was not an over-contribution | 277 |
| Tax Topics - General Concepts - Window Dressing | window-dressing is a deception about intention | 312 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | CRA’s assessing listed taxable RRSPs in a T3GR global return was not of the taxpayer’s (also listed) RRSP /inappropriate reliance in legal opinion on certificate of fact was carelessness | 441 |
| Tax Topics - Income Tax Act - Section 207.2 - Subsection 207.2(3) | CRA’s assessment of Pt. XI.1 shown on the T3GR for all RRSPs of one type did not start the normal reassessment period for the taxpayer’s RRSP since no tax shown for it | 370 |
| Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(d.2) | distribution was not lawful because the issuer had not complied with the OM exemption, which was the exemption that it had chosen to rely on | 290 |
Administrative Policy
20 April 2010 External T.I. 2010-0354681E5 - Part XI.1 Tax on RRSP Non-Qualified Investments
In response to a query as to whether Part XI.1 tax applies to a non-qualified investment if the property was a qualified investment at the time of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(10) | s. 146(10) is inapplicable if investment does not become non-qualified until after its acquisition | 91 |
25 June 2003 External T.I. 2003-0024465 F - PARTIE XI.1 BIENS NON-ADMISSIBLES
CCRA indicated that there is no provision under Part XI.1 allowing it to waive the tax thereunder, so that, to the extent that s. 207.1 applied to...
IC 78-14R4 Guidelines for trust companies and other persons responsible for filing T3GR, T3D, T3P, T3S, T3RI, and T3F returns 1 July 2006
Return filing requirement
1. Paragraph 150(1)(c), subsections 146.1(13.1) and 207.2(1) of the Income Tax Act, and section 204 of the Income Tax...
13 January 1993 T.I. 923826 (November 1993 Access Letter, p. 508, ¶C180-151)
When a public corporation is wound up, a share of the corporation cannot be removed from an RRSP's records and should be valued at its cost amount...
27 June 1991 T.I. (Tax Window, No. 4, p. 30, ¶1319)
RC will not apply s. 146(10) or s. 207.1(1) if an RRSP acquires real property as a result of foreclosure of a mortgage that was qualified property...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(10) | 53 |
Forms
T3GR Group Income Tax and Information Return for RRSP, RRIF, RESP, or RDSP Trusts (2011 version)
Required listing of taxable plans
Attach a list of all taxable RRSPs, RRIFs, RESPs, or RDSPs registered under this specimen plan or fund. The list...
Subsection 207.1(5)
Forms
T3GR Group Income Tax and Information Return for RRSP, RRIF, RESP, or RDSP Trusts
If you are required to pay tax under subsection 207.1(5), complete Form T2000, Calculation of Tax on Agreements to Acquire Shares. To report...