Revenu Canada Taxation Head Office
C. Robb (613)957-2744
November 21, 1989
XXXX
We are writing in response to your letter of October 18, 1989 wherein you have requested our views on whether participating mortgages are qualified investments for a Registered Retirement Savings Plan ("RRSP") under subparagraph 146(1)(g)(iv) of the Income Tax Act and subsection 4900(4) of the Income Tax Regulations.
In our view it is a question of fact whether a participating mortgage will be a qualified investment for a RRSP. It would be necessary to examine the specific agreements to determine whether or not the participating mortgage does give rise to an "equity" interest in the property.
We would be prepared to consider the matter further in the context of an advance income tax ruling.
Yours truly,
for Director Financial Industries Division Rulings Directorate