Subsection 204.2(1.2) - Undeducted RRSP premiums
Administrative Policy
7 July 1995 T.I. 5-951203 -
"A contribution to an RRSP will generally not be considered to have been made until the financial institution to which an amount is sent accepts the amount as a contribution ... [T]he designation of an amount as a contribution can be revoked by the contributor at any time before it is so accepted by the institution."
4 July 1994 T.I. 941444 (C.T.O. "Investment Counsel Fees")
The taxpayer claiming investment counsel fees must be the legal owner, i.e., the RRSP trustee, rather than the annuitant. If the annuitant pays the fees on behalf of the RRSP trust, the payment will be a gift made to the RRSP within the meaning of s. 204.2(1.2)I(b).