CRA registered fee folio delayed to summer

By Melissa Shin | June 26, 2017 | Last updated on October 27, 2023
3 min read

Advisors waiting for CRA to clarify how it will treat registered fees paid from open accounts will have to wait a little longer.

CRA now says it will release a folio dealing with its new position on the rules for RRSPs, RRIFs and TFSAs “by the end of summer 2017,” CRA spokesperson Lise Newton tells in an email. “To allow for further feedback from the tax community, the folio will have a three-month comment period.”

The agency told us in March that it would release the folio in spring 2016. With this revised timeline, the folio could be released as late as September 22.

What we know

In December 2016, we reported that CRA’s position had changed with regards to registered fees paid from open accounts. At the November 2016 Canadian Tax Foundation Conference, CRA told attendees that paying registered plan fees from non-registered accounts will incur a tax penalty equivalent to the fee.

CRA views the practice as creating an unfair advantage because it’s equivalent to a tax-free increase in the value of the registered plan. But the agency has yet to share guidance on how it will apply its new position, which comes into effect January 1, 2018.

The agency said it would be consulting with industry stakeholders before releasing the folio. One of those stakeholders was IFIC, which recommended that the advantage rules not apply to RRSPs and RRIFs, and that CRA delay implementing its new position past January 2018.

But Newton tells us that, so far, a January implementation is a go. Further, elements of the folio will be in force immediately.

“[A] new folio is not considered to be draft during the comment period, and can be relied upon as an accurate official summary of the CRA’s interpretation of the law from the date of application,” she says. “The proposed folio on advantages for RRSPs, RRIFs and TFSAs will be in effect at the time of publication except for the comments on investment management fees that are paid outside of a registered plan [emphasis added], which are specifically proposed to take effect on January 1, 2018.”

She explains January 1 was chosen “to allow sufficient time for the investment industry to adapt and for the change in CRA practice to take effect at the beginning of a tax year for individuals.”

Read: Why CRA should reconsider taxing RRSP fees paid from open accounts

The folio will be available on CRA’s website, and subject to a three-month comment period where people can “submit structure or content suggestions.” Comments should be sent to

Newton confirms that even though the folio will be in force, CRA will still consider those comments. “It is CRA’s practice to consider every comment received during the comment period of a folio and to change the folio where appropriate,” she says.

What advisors can do

James Carman, senior policy advisor of taxation at IFIC, told us earlier this month that once the folio is finalized, advisors should consider:

  • which fees are impacted;
  • how systems might need to change to capture relevant information;
  • which clients are affected;
  • what options exist for paying investment fees; and
  • how each client will pay fees going forward.

Also read: How Finance might curb tax advantages for private corps

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Melissa Shin

Melissa is the editorial director of and leads Newcom Media Inc.’s group of financial publications. She has been with the team since 2011 and been recognized by PMAC and CFA Society Toronto for her reporting. Reach her at You may also call or text 416-847-8038 to provide a confidential tip.