S. 146.2(6) provides that if a TFSA “carries on one or more businesses” then Part I tax is payable on its business income. What guidance is there respecting where taxpayers actively trade securities in their TFSA?
After noting that CRA has reassessed more than $75 million in additional taxes resulting from audits of TFSAs, CRA noted that, as indicated in S3-F10-C1, para. 1.87, “there is nothing unique in applying these general principles [set out in IT-479R] to securities trading that occurs within a registered plan.” Accordingly, CRA does not have any plan to provide any further guidance specific to TFSAs on this issue.