5-910247
Dear Madam:
This is in reply to your letter of January 8, 1991 asking if a participating mortgage would represent a qualified investment for a registered retirement savings plan ("RRSP").
Whether or not a participating mortgage will be a qualified investment for an RRSP under subparagraph 146(1)(g)(iv) of the Income Tax Act and subsection 4900(4) of the Income Tax regulations is a question of fact. It would be necessary to review the relevant agreements to determine whether or not the participating mortgage gives rise to an "equity interest" in the particular property, an unqualified investment.
We are prepared to consider the matter further in the context of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R2.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate