In a November 29, 2016 Technical Interpretation (2016-0670801C6, Wurtele, Dave), CRA opined that the advantage tax rules (Subsection 207.01(1)) would likely apply where investment management fees incurred by an RRSP, RRIF or TFSA are paid from outside of the plan by the annuitant or holder.
In these cases, the plan’s controlling individual could be subject to an advantage tax of 100% of the amount of the fees paid (Section 207.05).
CRA will defer the application of this position until January 1, 2018.
For further information see Video Tax News Monthly Tax Update Newsletter, Issue No. 427