20 August 2009 External T.I. 2008-0294531E5 F - Placement admissible REÉR - Parts privilégiées RIC -- summary under Subsection 146(5)

Regarding preferred shares issued by a cooperative to a purchaser who commits at a later date to pay for the shares, but in the meantime transfers the shares to the purchaser’s RRSP, CRA stated that it was not within its purview to comment on whether, under Quebec law, such shares were validly issued. If there was a resulting contribution to the RRSP, “the proceeds of disposition and the amount of premium considered to be paid are equal to the fair market value of the property transferred or contributed by the taxpayer at the time of its disposition.”