Regulation 4900

Subsection 4900(1)

Paragraph 4900(1)(b)

Administrative Policy

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

Back-dating rule effective for Reg. 4900(1)(b) purposes

1.24 The post-amble of the public corporation definition in subsection 89(1) allows a new...

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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 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

24 June 1994 External T.I. 9409235 - MUTUAL FUND UNITS AS QUALIFIED INVESTMENT FOR RRSP

Because one of the criteria in s. 131(8)(a) is that the corporation be a public corporation, a share of a mutual fund corporation will be a...

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23 February 1994 External T.I. 9402255 - HAA2255-7 RRSP INVESTMENTS PUBLIC CORPORATIONS

A corporation can verify its status as a public corporation through the District Office at which it files its returns. Many RRSP trustees will...

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1 June 1993 Income Tax Severed Letter 930642A F - Qualified Investment

Shares represented by an instalment receipt and that are pledged to a seller of shares to secure the obligation of the holder to pay the unpaid...

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13 January 1993 T.I. (Tax Window, No. 28, p. 18, ¶2397)

The delisting of a share, the suspension of its trading or the bankruptcy of the corporation will generally not cause the share to become an...

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7 April 1992 T.I. (Tax Window, No. 18, p. 18, ¶1867)

Escrowed shares may constitute a qualified investment.

7 November and 19 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 19, ¶1060)

Where shares of a corporation are not qualified at the time of acquisition because the corporation is not a public corporation, they cannot become...

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4 July 1989 T.I. (Dec. 89 Access Letter, ¶1058)

Shares of a class which are not listed on an exchange are qualified investments where shares of another class of the corporation are listed.

Paragraph 4900(1)(d)

Administrative Policy

11 January 2002 External T.I. 2001-0106745 - MFI CLASS OF UNITS QUALIFIED INVESTMENT

Units from a mutual fund trust's different classes of units will satisfy Regulation 4900(1)(d) even if a particular class does not satisfy the...

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Paragraph 4900(1)(d.1)

Administrative Policy

4 December 2000 External T.I. 2000-0054365 - MUTUAL FUND TRUST PRES. STOCK EXCH.

"Since debts of a public corporation that only has one class of shares that trade on a prescribed stock exchange will be a qualified investment...

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Paragraph 4900(1)(d.2)

See Also

Grenon v. The Queen, 2021 TCC 30

The taxpayer’s RRSP invested in units of units trusts (the “Income Funds”) which Smith J found were not units of mutual fund trusts and,...

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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 755
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 207.1 - Subsection 207.1(1) non-qualified investments not “included” in annuitant’s income because it was never assessed 346
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

Paragraph 4900(1)(e)

Administrative Policy

12 June 2002 External T.I. 2002-0138625 - REGISTERED INVESTMENTS FUTURES CONTRACTS

CRA indicated that whether currency and interest rates futures contracts are prescribed investments for a registered investment (i.e., under Reg,...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 4901 - Subsection 4901(1) whether currency and interest rates futures contracts are prescribed investment turns on Reg. 4900(1)(e) (likely, yes) 160

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

Writing puts and calls not subject to rules

1.40 When writing put and call options ... , no property is actually acquired by the option writer at...

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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 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

15 March 2010 External T.I. 2009-0345001E5 - Qualified Investment for a RRSP

Are subscription receipts issued by a private Canadian corporation qualified investments under Reg. 4900(1)(e) if they entitle the holder to...

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1 August 2007 External T.I. 2007-0247291E5 - Qualified Investments - Subscription Receipts

Are subscription receipts that provide the holder with the right to receive a cash settlement in lieu of delivery of the underlying property,...

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24 March 1997 External T.I. 9705785 - SPECIAL WARRANT, QUALIFIED INVESTMENT

The underlying property must be a qualified investment throughout the period that the warrant or right is held by the RRSP. Accordingly, where the...

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31 October 1996 T.I. 962433 (C.T.O. "RRSP Options")

Because shares of a corporation listed on a prescribed stock exchange outside of Canada are qualified investments under paragraph (a) of the...

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30 January 1995 External T.I. 9430685 - RRSP QUALIFIED INVESTMENTS - PUTS & CALLS

Index options are not qualified investments for an RRSP except in respect of the particular time, if any, when it can be clearly established that...

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27 October 1994 Internal T.I. 9421586 - REGISTERED INVESTMENT AND STOCK INDEX FUTURES CONTRACT

A stock index futures contract is not a qualified investment for a deferred income plan or a prescribed investment for a registered investment.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 132 - Subsection 132(6) stock index futures 16
Tax Topics - Income Tax Act - Section 204.6 - Subsection 204.6(1) no tax under s. 204.6 if qualify as an MFT/tax for quasi-MFT re futures contract based on transaction costs 139

27 October 1994 External T.I. 9427105 - OPTIONS AS RRSP QUALIFIED INVESTEMENTS

If the subject of a call option is a qualified investment, the call options is a qualified investment. However, a put option is property which is...

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24 October 1994 External T.I. 9426305 - CONVERTIBLE DEBENTURES AS QUALIFIED INVESTMENTS

A debenture that is convertible into shares of an eligible corporation or shares of a small business corporation will not qualify under Regulation...

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31 August 1994 External T.I. 9420195 - TSE 35 PUT WARRANTS, QUALIFIED INVESTMENTS FOR RRSPS

TSE 35 index warrants "would not be qualified investments for an RRSP except in respect of a particular time, if any, when it can be clearly...

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

A put option is not a qualified investment as it is a right to dispose of, rather than to acquire, a security.

92 C.R. - Q.51

A "poison pill" warrant that cannot be severed from the share to which it relates and that, therefore, cannot itself be listed, will not be a...

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31 July 1991 T.I. (Tax Window, No. 7, p. 21, ¶1380)

Rights of shareholders to acquire additional shares at a discount in the event of a take-over bid do not meet the requirements of Regulation...

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6 June 1990 T.I. (November 1990 Access Letter, ¶1540)

Nikkei put warrants are not qualified investments because they do not give the owner the right to acquire a qualified investment at all times.

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

Re eligibility of listed warrants or call options.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) 39

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

Where in an issue of shares and warrants, separate trading of the warrants and shares for a period of time, typically thirty days, is prohibited...

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Articles

Leslie Morgan, "Warrants, Rights and Options as Qualified Investments", Corporate Finance, Vol. XII, No. 1, 2004, p. 1158.

Paragraph 4900(1)(g)

Administrative Policy

25 June 1991 T.I. and May 1991 Question and Answer (Tax Window, No. 3, p. 23, ¶1225)

Bonus interest paid by a credit union on invested funds which remain in the RRSP will not cause the investment to be non-qualified, nor will a...

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Paragraph 4900(1)(i)

Administrative Policy

12 May 1995 External T.I. 9513105 - REGISTERED CHARITY DEBENTURES FOR RRSP

Debentures issued by a non-profit, non-share corporation that are not guaranteed by any third party will not be qualified investments.

11 October 1994 Internal T.I. 9417147 - RRSP QUALIFIED INVESTMENT IN DEBENTURES

A debenture from a Canadian subsidiary of a corporation whose shares are listed on the Vancouver Stock Exchange is a qualified investment for an...

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21 December 1993 T.I. HAA7255-7 (C.T.O. "Interest in a Bond as Qualified Investment for RRSP")

"An 'interest' in a bond or similar obligation that is a qualified investment for an RRSP pursuant to paragraph 4900(1)(i) of the Income Tax...

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Paragraph 4900(1)(j)

See Also

Stewart v. The Queen, 2019 TCC 22

A corporation that was unrelated to the taxpayers (“Zowtra”) granted a mortgage for $1.8 million (the “Zowtra Mortgage”) on Alberta lands...

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Words and Phrases
mortgage
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(9) - Paragraph 146(9)(b) mortgage issued in scam had full FMV until the funds were stolen 415
Tax Topics - General Concepts - Fair Market Value - Other mortgage issued in a scam had full FMV 238

Administrative Policy

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

Acquisition of real estate on default

1.34 Real or immovable property is not a qualified investment for a registered plan. However, a registered...

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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.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 January 2004 External T.I. 2003-0047381E5 F

CCRA indicated that the interest paid to an RRSP on a mortgage would not constitute a premium as to the portion of that interest that exceeded a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(1) - Premium interest received by lender to an RRSP in excess of market rate is not a “premium” 33

13 July 1994 Internal T.I. 9415727 - RRSP INVESTMENT INTEREST IN NON-ARM'S LENGTH MORTGAGE

Two RRSPs can each hold an interest in a single mortgage provided each interest is owned by the respective RRSP and all of the remaining...

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8 February 1994 External T.I. 9400615 - RRSP QUALIFIED INVESTMENT- MORTGAGE

A mortgage on a business property can be a qualified investment for an RRSP even where the mortgagor and the annuitant do not deal at arm's...

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Paragraph 4900(1)(j.1)

Administrative Policy

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

Approved lender/market interest

1.36 ... The list of approved lenders is available on the CMHC website. The interest rate and other terms must...

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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 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

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 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
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

Paragraph 4900(1)(p.1)

Articles

D. Louis, "Trick or Treat? - RRSPs and Foreign Index Units", The Estate Planner, No. 46, November 13, 1998, p. 6.

Paragraph 4900(1)(u)

Administrative Policy

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

RCM coins

1.52 A legal tender gold or silver bullion coin produced by the Royal Canadian Mint with a minimum purity of 99.5% for gold and 99.9%...

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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)(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

Paragraph 4900(1)(v)

Administrative Policy

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

RCM certificates

1.54 A gold or silver certificate issued by the Royal Canadian Mint or a specified corporation is a qualified investment if the...

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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 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

Subsection 4900(2)

Administrative Policy

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

Sub of rating agency may be accepted

1.31 ... Where the facts, corporate structure and legal relationship make it clear that a listed rating...

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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(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

designated shareholder

Administrative Policy

22 February 1990 T.I. (July 1990 Access Letter, ¶1337)

Where one of a group of employees owns 49% of the shares of the corporation, another unrelated employee owns 5%, and the remaining voting shares...

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Subsection 4900(4)

Cases

Millward v. The Queen, 86 DTC 6538, [1986] 2 CTC 423 (FCTD)

A company owned by the taxpayer mortgaged land in favour of an RRSP of the taxpayer's partner ("Coates") in his law firm and a company owned by...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) acting in concert where mutual back scratching 132

The Queen v. Epstein, 84 DTC 6259, [1984] CTC 270 (FCTD)

It was held that the word "mortgagor" in an ancestor of regulation 4900(4) should be taken to refer only to the person who first grants the...

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Words and Phrases
mortgagor

Administrative Policy

19 September 1996 External T.I. 9629885 - RRSP MORTGAGE ON LEASEHOLD INTEREST

Where a building built by a lessee on land situate in Canada qualifies as a leasehold interest or other real property, rather than as a chattel,...

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21 July 1995 External T.I. 9516095 - NON-RECOURSE MORTGAGE

A non-recourse mortgage secured by real property is considered a mortgage for purposes of Regulation 4900(4).

8 February 1994 External T.I. 9400195 - RRSP - MORTGAGE AS QUALIFIED INVESTMENT

A mortgage will be a qualified investment for an RRSP where the annuitant is a member of a church and the church is the mortgagor, provided that...

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26 November 1992 T.I. 923059 (September 1993 Access Letter, p. 422, ¶C144-237)

An investment of an RRSP in a fund that invested only in mortgages, where there was no evidence that the fund would hold the mortgages as nominee...

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

The greater the difference between the relevant commercial interest rate at the time of a mortgage loan and the interest rate offered, the more...

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11 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 22, ¶1089)

Where an RRSP becomes a mortgagee in possession and is required to make expenditures to maintain the property, if such payments are added to the...

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Subsection 4900(6)

Administrative Policy

18 April 1990 T.I. (September 1990 Access Letter, ¶1430)

Re eligibility of the shares of a Quebec business investment company.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Shares 51

2 November 89 T.I. (April 1990 Access Letter, ¶1191)

A person's dual status as both an employee and a shareholder of a corporation will not by itself cause the share to lose its status as a qualified...

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Subsection 4900(12)

Administrative Policy

2001 Ruling 2001-0070523 - REAL ESTATE DEVELOPMENT ACTIVE BUSINESS

Shares of a corporation that was in the process of developing a parcel of land into a retirement community with a view to selling homes and...

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Income Tax Technical News, No. 9, 10 February 1997

Where two unrelated shareholders each own 50% of the shares of a corporation, the fact that they used their own RRSPs to acquire shares of the...

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Subsection 4900(13)

Subsection 4900(14)

Paragraph 4900(14)(a)

Subparagraph 4900(14)(a)(iii)

Administrative Policy

14 October 2009 External T.I. 2009-0325101E5 F - Placement admissible, part de coopérative

CRA indicated that both of the conditions of the definition of "qualifying share" in Reg. 4901(2)(a) and (b) need not be satisfied in order for a...

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Subsection 4900(15)

Administrative Policy

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

Respecting whether shares of a co-operative corporation may be prohibited investments under s. 207.01(1)(d) of the definition "prohibited...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder investor in cooperative holds shares and is shareholder 181
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Prohibited Investment - Paragraph (b) - Subparagraph (b)(i) share of cooperative can be a share of corporation for prohibited investment purposes 71

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