MEMORANDUM
DATE September 22, 1988
SASKATOON DISTRICT OFFICE E.& O.E.
FROM HEAD OFFICE Financial Industries Division R. Nanner (613)957-3494
Attention: A. Mackisey
SUBJECT - RRSP XXXX
This is in response to your R.T.M. of July 27, 1988 wherein you requested us to reply to the letter dated July 20, 1988 from XXXX in respect of XXXX registered retirement savings plan's proposed investment.
Since the letter contemplates a proposed transaction, it should be in the form of a ruling request which we are willing to entertain provided it is in accordance with Information Circular 70-6R. We do, however, offer the following general comments.
A non-arm's length mortgage may be a qualified investment for an RRSP provided it meets the requirements of paragraph 4900(1)(j) of the Income Tax Regulations and paragraph 8 of the Special Release dated May 25, 1984 to IT-320R .
Please advise the taxpayer accordingly.
for Director Financial Industries Division Rulings Directorate