F. Francis
(613) 957-349619(1)
June 27, 1989
Dear Sirs:
This is in reply to your letter of May 15, 1989 wherein you requested our opinion on whether the common shares of 24(1) would be a qualified investment for a registered retirement savings plan ("RRSP").
As noted in Information Circular 70-6R, we do not give opinions in respect of specific proposed transactions other than as a reply to an advance income tax ruling request. As a consequence thereof, we will only offer the following general comments.
Pursuant to paragraph 4900(1)(b) of the Income Tax Regulations, a share of the capital stock of a public corporation is prescribed to be a qualified investment for RRSPs. The term "public corporation" is defined under paragraph 89(1)(g) of the Income Tax Act (the "Act").
Provided that the above-noted company qualifies as a public corporation for purposes of the Act, the common shares would not be qualified investments for RRSPs notwithstanding that the shares are not listed on a prescribed stock exchange in Canada.
We trust the above comments will be of assistance to you.
Yours truly,
Wayne Douglas for Director Financial Industries Division Rulings Directorate