28 October 2008 External T.I. 2008-0274281E5 F - Société gestion de pension, moyen de financement -- summary under Subparagraph 149(1)(o.1)(ii)

In the course of a general response, CRA stated:

[A] management corporation that provides only accounting and lease management services would not be accepted by the Minister as a funding medium for the purposes of registering a pension plan since the corporation does not hold property.