18 January 2010 External T.I. 2009-0340431E5 F - REER, exploitation d'une entreprise -- summary under Subsection 146.2(6)

When asked to confirm the tax consequences related to speculative trading activities carried out in a tax-free savings account, CRA stated.

A trust governed by an RRSP or TFSA that carries on a business will have tax payable under Part I of the Act on its taxable income from carrying on the business. … This trust will be eligible for the deduction under paragraph 104(6)(b) only to the extent that it has amounts of income that have become payable to a beneficiary. … Subsection 150(3) specifies that every agent or other person administering, managing, winding up, controlling or otherwise dealing with the property, business, estate or income of a person who has not filed a return for a taxation year shall file a return in prescribed form of that person’s income for that year.

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