21 April 1988 Income Tax Severed Letter 7-2693 - [Instalment Receipts]

By services, 22 July, 2022
Official title
[Instalment Receipts]
Language
English
Document number
Citation name
7-2693
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657968
Extra import data
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"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1988-04-21 08:00:00",
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Main text

Revenue Canada Taxation Head Office

MEMORANDUM

DATE April 21, 1988

TO - OTTAWA DISTRICT OFFICE 

FROM - HEAD OFFICE
               Financial Industries Division 
                R. Manner
                957-3494
Attention: M. Mahoney
           Info. 1, 2nd Floor

SUBJECT/ Instalment Receipts (Installment Receipts)

This is in response to your memorandum of March 3, 1988 requesting our comments as to whether the above-mentioned Instalment Receipts are a qualified investment for the purposes of paragraph 4900(1)(e) of the Income Tax Regulations (the "Regulations").

Based on the Information on file, it is our opinion that provided the Instalment Receipts are listed on a prescribed stock exchange, they would be a qualified property; however, if a registered retirement savings plan ("RRSP") acquires this property, section 206.1 would apply to the RRSP. Consequently, the RRSP will be subject to tax equal to 1% per month of the maximum amount that the RRSP is or may be required to pay for the underlying shares that it may acquire pursuant to the agreement in connection with the Instalment Receipts.

We hope the above comments are of assistance to you.

for Director Financial Industries Division Rulings Directorate