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ARTICLE · 29 JULY 2025

Mr. Grenon's Legendary RRSP And Its Implications For Fund Manufacturers

Borden Ladner Gervais LLP
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On July 4, 2025, the Federal Court of Appeal (the Court) released its long-awaited decision in The RRSP of James T. Grenon by its trustee CIBC Trust Corporation v. His Majesty the King (Grenon).

CanadaTax
Grace Pereira
Grace Pereira
Tony Zhang
Tony Zhang
Benjamin (Ben) Kastelyanets (Summer Law Student)
Benjamin (Ben) Kastelyanets (Summer Law Student)
Pamela Cross
Pamela Cross
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On July 4, 2025, the Federal Court of Appeal (the Court) released its long-awaited decision in The RRSP of James T. Grenon by its trustee CIBC Trust Corporation v. His Majesty the King (Grenon). Grenon is the first court decision to consider the requirements of the mutual fund trust definition in the Income Tax Act (ITA) and its associated requirements in the Income Tax Regulations (ITR) and, as such, has implications for both (i) fund manufacturers (as discussed below) and (ii) trustees of registered plans and their administrative agents (as discussed in a separate BLG bulletin).

Requirements to be a "mutual fund trust" for tax purposes

Trusts are the most popular Canadian investment fund vehicle. One of the reasons for their popularity over other forms of fund structures is that units of certain types of trust funds, such as those that are "mutual fund trusts" for tax purposes, are "qualified investments" for registered plans.

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