At the 2010 APFF Financial Strategies and Instruments Roundtable, a Finance representative indicated that one of the factors which CRA could take into account in determining whether an HBP withdrawal made after January of a year was to be deemed under s. 146.01(2)(d) to have been received at the end of the preceding year, was whether the RRSP balance at that year end was sufficiently elevated to support that withdrawal. If often occurs that a purchase that is made in one year does not close until after January of the following year.
If the RRSP balance on December 31, 2017 is sufficient to cover the RRSP withdrawal subsequent to January of 2018, will CRA automatically apply its discretion under s. 146.01(2)(d) such that the withdrawal is deemed to have been made at the end of 2017; and which other factors if any does CRA take into account in exercising that discretion? CRA responded:
The mere fact that, in the situation described, the RRSP balance at December 31, 2017 is sufficient to cover the RRSP withdrawal made in 2018, at a time that is after January 2018, would not, in itself, be sufficient for that Ministerial discretion to be automatically applied, since only a full examination of the facts and circumstances of a particular situation can permit the exercise of that discretion.
In exercising her discretion, the Minister may consider, in addition to the RRSP balance at December 31, 2017, the dates on which the amounts required for withdrawal were contributed and the reasons for the withdrawals being made over a period that straddled two calendar years. However, this is not an exhaustive list. …
HBP participants who withdraw over more than one year will generally be contacted by the CRA to confirm details of their participation.