Subsection 4900(1)
Paragraph 4900(1)(b)
Administrative Policy
S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs 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...
24 June 1994 External T.I. 5-940923
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...
23 February 1994 External T.I. 5-940225
A corporation can verify its status as a public corporation through the District Office at which it files its returns. Many RRSP trustees will...
1 June 1993 External T.I. 5-930642
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...
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...
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...
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. 2001-010674
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...
Paragraph 4900(1)(d.1)
Administrative Policy
4 December 2000 External T.I. 2000-005436
"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...
Paragraph 4900(1)(e)
Administrative Policy
S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs 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...
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...
1 August 2007-T.I. 0247291E5 [right under subscription receipt to receive cash]
Are subscription receipts that provide the holder with the right to receive a cash settlement in lieu of delivery of the underlying property,...
24 March 1997 T.I. 970578 [special warrant before prospectus cleared]
The underlying property must be a qualified investment throughout the period that the warrant or right is held by the RRSP. Accordingly, where the...
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...
30 January 1995 T.I. 943068 (C.T.O. "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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(10) | 75 | |
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) | 18 | |
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(9) | 44 |
27 October 1994 Internal T.I. 7-942158
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) | 35 |
27 October 1994 T.I. 942710 (C.T.O. "Options as RRSP Qualified Investments")
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) | 23 | |
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(9) | 17 |
24 October 1994 T.I. 942630 (C.T.O. "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...
31 August 1994 External T.I. 5-942019
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...
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 36 | |
| Tax Topics - Income Tax Act - Section 49 - Subsection 49(1) | 23 |
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...
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 204 - qualified investment - (d) | 26 |
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...
Paragraph 4900(1)(i)
Administrative Policy
12 May 1995 T.I. 951310 ("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 Memorandum 941714 (CTO RRSP Qualified Investment in Debentures") and 13 September 1994 GAAR Committee Report 941714 (CTO "Debt Invested in U.S. as RRSP Qualified Investment")
A debenture from a Canadian subsidiary of a corporation whose shares are listed on the Vancouver Stock Exchange is a qualified investment for an...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 206 - Paragraph 206(1)(d.1) | 162 |
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...
Paragraph 4900(1)(j)
Administrative Policy
S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs 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...
13 July 1994 Internal T.I. 7-941572
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...
7 February 1994 External T.I. 5-940061
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...
Paragraph 4900(1)(j.1)
Administrative Policy
S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs 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...
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...
| 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) - RRSP 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, FHSAs 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%...
Paragraph 4900(1)(v)
Administrative Policy
S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs 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...
Subsection 4900(2)
Administrative Policy
S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs 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...
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...
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...
| 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 | 128 |
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 17 | 21 |
Administrative Policy
19 September 1996 External T.I. 5-962988
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,...
21 July 1995 T.I. 951609 (C.T.O. "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. 5-940019
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...
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...
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...
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...
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...
Subsection 4900(12)
Administrative Policy
2001 Ruling 2001-007052
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...
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation - Federal - Indian Act - Section 87 | 26 | |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) | events must be beyond borrower's control | 77 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | loss transfer must be to affiliated person - related not enough | 48 |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | 69 | |
| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c.3) - Subparagraph 88(1)(c.3)(ii) | 151 |
2 September 1994 External T.I. 5-942028
General discussion.
Subsection 4900(13)
Administrative Policy
1996 A.P.F.F. Round Table 7M12910 (Item 4.4.3)
One cannot conclude simply from the fact that a start-up corporation pays little salary to an individual who is a beneficiary of an RRSP holding...