15 March 2010 External T.I. 2009-0345001E5 - Qualified Investment for a RRSP -- summary under Paragraph 4900(1)(e)

Are subscription receipts issued by a private Canadian corporation qualified investments under Reg. 4900(1)(e) if they entitle the holder to acquire treasury shares of the corporation after they become listed on a designated stock exchange? CRA stated:

[T]his paragraph requires that the underlying property to be acquired by the option, warrant or similar right must be a qualified investment the entire time the subscription receipt is held by the trust governed by an RRSP.

...[T]he underlying properties of the subscription receipts are treasury shares of a corporation which will only be a qualified investment when they become listed on a designated stock exchange. Therefore...until the treasury shares are listed on a designated stock exchange, the subscription receipts would not provide the right to acquire properties that are qualified investments and would not be qualified investments pursuant to paragraph 4900(1)(e)... .

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