The uncertainty of whether an advantage tax is created when the payment of investment management fees occurs from outside of a registered account appears to be over. Examples of registered accounts include:
- Registered Retirement Savings Plan (“RRSP”);
- Registered Retirement Income Fund (“RRIF”);
- Tax Free Savings Account (“TFSA”);
- Registered Education Savings Plan (“RESP”); or
- Registered Disability Savings Plan (“RDSP”).
The Canada Revenue Agency (“CRA”) released a comfort letter on August 26, 2019, stating no advantage will be considered to have taken place in these circumstances.