The taxpayer was a sophisticated investor. In 2009, when the Tax-Free Savings Account (“TFSA”) rules were introduced, she saw a tax planning opportunity. At that time, she had a self-directed RRSP and a direct trading account. Knowing that gains made inside TFSAs are not taxable, she swapped stocks in and out of her RRSP, trading account and newly opened TFSA to take advantage of that.
HKL Tax Law
Montreal Tax Lawyer