Regulation 5100

Eligible Corporation

Administrative Policy

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

Eligible corporations

1.66 ... The conditions are comparable to those described ... for specified small business corporations, except that they must be satisfied not only at the time of acquisition but throughout the entire period during which the shares are held by the RRSP, RRIF or RESP. ...

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 204 - qualified investment - (a) 208
Tax Topics - Income Tax Act - Section 262 113
Tax Topics - Income Tax Act - Section 204 - qualified investment - (d) 320
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(b) 256
Tax Topics - Income Tax Act - Section 204.4 - Subsection 204.4(1) 107
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(2) 52
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j) 149
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j.1) 53
Tax Topics - Income Tax Act - Section 204 - qualified investment - (b) 55
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(e) 173
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (b) 69
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(u) 80
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(v) 50
Tax Topics - Income Tax Regulations - Regulation 4901 - Subsection (1) - Specified small business corporation 38
Tax Topics - Income Tax Act - Section 207.04 - Subsection 207.04(4) 82
Tax Topics - Income Tax Act - Section 146 - Subsection 146(10.1) 90
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(6) 110
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(a) 118
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(b) 94
Tax Topics - Income Tax Act - Section 146.2 - Subsection 146.2(6) 156

1 November 1994 T.I. 942012 (C.T.O. "Def'n of Eligible Corporation")

If the shares of a non-Canadian corporation represent more than 10% of the property of a corporation, that corporation will not be an eligible corporation. "In determining whether 'all or substantially all' of the property of a corporation is used for an eligible purpose, it is generally our view that this criterion will be satisfied where 90% or more in terms of the total cost of the corporation's assets is used for an eligible purpose. However, a determination made on some other reasonable basis that is more appropriate than cost in a particular situation may also be acceptable."

3 September 1992 T.I. (Tax Window, No. 24, p. 6, ¶2197)

RC recognizes that at certain points in the business cycle a business may have unusually high levels of cash or short-term investments without it necessarily losing its status as an eligible corporation.

Qualifying Active Business

Administrative Policy

21 July 1997 T.I. 971913

In response to an inquiry as to whether an investment in a golf club was a qualified investment for an RRSP, it was noted that such an entity, which is incorporated for purposes other than carrying on a trade or business, may not meet the requirements of the definition of qualifying active business.

17 February 1994 External T.I. 5-940152 -

An entity, such as a club, which was incorporated for purposes other than carrying on a trade or a business, may not meet the requirements for a qualifying active business.

3 September 1992 T.I. (Tax Window, No. 24, p. 6, ¶2197)

Paragraphs (c) and (d) of the definition of qualifying active business are not intended to exclude the application of any other reasonable text in determining whether a business is being carried on primarily in Canada.

22 March 1991 T.I. (Tax Window, No. 1, p. 20, ¶1165)

A real estate brokerage business is not described in paragraph (b).

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