Does CRA accept comments in Prochuk for the proposition that day trading in an RRSP trust does not result to carrying on a business for the purpose of 146(4)b)?
After noting that the case did not change its position that day trading in an RRSP was a business (as the conclusion reached in the case was limited to day trading in an RRSP not being a relevant factor to determining whether an individual is carrying on a business outside of the plan), CRA then paraphrased s. 146(4)(b) and stated (TaxInterpretations translation):
This signifies that if an RRSP trust carries on speculative day trading activities, it does not have income tax payable on its income derived from its business on condition that the activities of the business are limited to the purchase and sale of qualified investments… .