| 19(1) | 5-901842 |
| J. Stalker | |
| (613) 957-9796 |
October 29, 1990
19(1)
We are writing in response to your letter of, August 2, 1990 concerning Self-Directed Retirement Savings Plans (SDRSPs).
You asked for our opinion on whether an arms-length mortgage held in a SDRSP which is in arrears for more than three months would be considered a qualified investment, as defined in paragraph 146(1)(g) of the Income Tax Act (Canada) (the "Act").
In our view, provided the mortgagor deals with the annuitant of the SDRSP at arms-length, a mortgage in arrears for more than three months would be a qualified investment for the purposes of paragraph 146(1)(g) of the Act.
Our comments are provided pursuant to the practice referred to in paragraph 21 of Information Circular 70-6R2.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate