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Money Badger Mafia

The Smith Manoeuvre

This desk carries its own line rate, its own marginal rate and its own picked draws — the Bookie's margin numbers stay separate.

Following the Bookie's 36% until you set one here. Save a T4 or other income slip for this year to read your stacked bracket.

Investment debt

$0

Deductible side · line 22100

Personal debt

$0

Not deductible, tracked anyway

Margin draws, payments and the carry math live at The Bookie. Rates set here stay on this desk; tick which loan-book draws belong to the plan below.

Pulled straight from the Accountant so the deduction math uses your real bracket.

No forms saved for 2026. Add them on The Accountant and they land here automatically.

2026 wages $0 · stacked marginal

Turn the mortgage into a deductible investment loan, one principal payment at a time. Estimates, not tax advice.

Loan used

$0.00

Smith draws ticked below

Still available

No limit on file

Put your approved line limit in to track room left to readvance.

Book it on the Smith line

Buys off the line and payments against it. These land here only — the Bookie's margin line stays clean.

Smith line owing

$0.00

Interest accrued $0.00 at 6.95%

Interest paid

$0.00

Worth $0.00 back on 22100

  • Nothing on the Smith line yet. Book a draw when you readvance and invest it.

Put the mortgage balance and monthly payment in to run the conversion.

The rules the claim lives or dies on. Plain language, with the cite.

Line 22100 — carrying charges and interest

ITA 20(1)(c) · T1 line 22100

Interest paid or payable on money borrowed to earn income from a business or property is deductible on line 22100. You claim it in the year it is paid (cash basis) or payable (accrual), consistently. Keep the statements.

Direct use / current use test

Folio S3-F6-C1

Deductibility follows what the borrowed dollars actually bought, not what secured the loan. A HELOC on your house used to buy dividend ETFs is deductible; the same HELOC used for a truck is not.

Tracing and mixed use

Folio S3-F6-C1, para 1.29-1.42

Mixing personal and investment draws in one line forces a pro-rata allocation and invites a reassessment. Keep a separate sub-account or segment for the investment borrow, and never park personal spending in it.

Reasonable expectation of income

Ludco Enterprises v Canada, 2001 SCC 62

There must be a reasonable expectation of gross income — not net profit. Interest can exceed the distributions received and still be deductible, provided the investment can pay income at all.

Refinancing your own home equity

Singleton v Canada, 2001 SCC 61

Repaying non-deductible debt with cash and re-borrowing to invest is respected when the transactions are legally distinct and properly documented. Order and paperwork are everything.

GAAR and the Smith Manoeuvre

Lipson v Canada, 2009 SCC 1

The general anti-avoidance rule can bite when the structure exists mainly to shift a deduction between spouses. A straight single-taxpayer conversion of mortgage debt into an investment loan has long been accepted; spousal loan variants need advice.

Return of capital grinds your claim

Folio S3-F6-C1, para 1.43-1.45 (disappearing source)

ROC distributions are a partial return of borrowed capital. CRA's position is that ROC used for personal spending reduces the deductible portion of the loan. Reinvest ROC or apply it against the line to keep the full deduction alive.

Disappearing source rule

ITA 20.1

If the investment is sold at a loss or wound up, section 20.1 can preserve interest deductibility on the remaining borrowing that is deemed to still be used for income purposes. Track proceeds and where they go.

Registered accounts are out

ITA 18(11)

Interest on money borrowed to contribute to a TFSA, RRSP, RESP, FHSA or RDSP is never deductible. Only borrow into the non-registered book if you want the write-off.

Capitalized interest

Folio S3-F6-C1, para 1.79-1.82

Interest that is added to the loan balance rather than paid in cash can still be deductible, and interest on that capitalized interest is generally deductible too — but only where the underlying borrowing qualifies and the line permits it.

Readvanceable mortgage mechanics

Lender product terms

A readvanceable mortgage frees credit room equal to each principal payment. Re-borrowing that room to invest is the engine of the Smith Manoeuvre; the mortgage half stays non-deductible until it is fully retired.

Superficial loss

ITA 54, 40(2)(g)(i)

Selling at a loss and rebuying the same security within 30 days (by you or an affiliated person, including your RRSP or TFSA) denies the capital loss and adds it to the ACB of the repurchased shares.

Investment counsel fees

ITA 20(1)(bb)

Fees paid for advice on buying or selling specific securities in a non-registered account are deductible on line 22100. Commissions are not — they ride in the ACB. MER inside an ETF is already netted out of NAV and is not separately claimable.

Documentation the auditor wants

Practice

Loan agreement, statements showing each advance, the trade confirmation the advance funded on the same or next day, and a written allocation memo. That chain is what makes line 22100 survive review.

General information only, not tax advice. Confirm with your accountant before you claim.

Prime moved? Post the change and only the days after it re-price.

Opening

6.95%

In force today

6.95%

Blended 2026

6.95%

Interest accrues actual/365 on the balance standing each day at the rate posted for that day. The CRA interest schedule splits each period again at every rate change, so the line 22100 paperwork shows exactly what was charged and when.

Smith HELOC. Direct tracing under s.20(1)(c) and the current use rule, Folio S3-F6-C1. Not tax advice.

Borrowed at work

$0

In open lots

Offside principal

$0

Interest not deductible

Sales to square

0

No use declared

Parked in cash

$0

Waiting on an eligible buy

Nothing borrowed has been sold yet. Every draw still traces straight to the lot it bought.

Not financial or tax advice. Money Badger Mafia is a personal portfolio tracker, not a financial advisor, tax professional, or registered investment adviser. Every number here — prices, yields, ACB, tax estimates, CRA line items — is only as accurate as what you type in or import. Miss a slip, mis-key a box, or import a stale statement and the output will be wrong even though the math is right. Nothing here is filed, reviewed, or blessed by the CRA. Check your own paperwork and have a qualified tax professional verify everything before you file or make a money decision.

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