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Objective — convert existing non-deductible personal debt into deductible investment debt, without changing how much is owed or how much is invested.

Risk level — 1 — Low risk. Risk justification — total debt and total market exposure are unchanged; only the tax character of the interest changes. It is level 1 rather than level 0 because the conversion transaction crystallizes a capital gain and the deduction depends on tracing that can fail. Benefit justification — unverified — needs Talbot. Jurisdiction — Canada. The strategy exists because Canada denies personal-residence mortgage interest deductibility while allowing investment-interest deductibility; it does not transfer to the U.S. unexamined.

  • An existing non-deductible debt balance (mortgage, personal line of credit).
  • Existing non-registered investments that can be sold.
  • Borrowing capacity to re-borrow after repayment.

Sell investments → use the proceeds to pay down the non-deductible debt → immediately re-borrow against the freed equity → reinvest. The new borrowing’s interest is deductible because it is traceable to an income-producing investment.

The distinguishing feature against the Smith Manoeuvre: Debt Swap starts from an existing non-deductible balance and converts it in a one-time (or periodic) transaction. The Smith Manoeuvre converts gradually, driven by a mortgage’s own amortization schedule.

  • Converts the tax character of interest already being paid, with no increase in leverage.
  • At the Ontario top rate, deductibility takes the effective cost of a 7% loan from 7% to 3.25% (canada-investment-taxation.md §9.2).
  • The sale is a taxable disposition. The capital gain is crystallized now, in exchange for a future stream of deductions.
  • Deductibility depends on the tracing surviving the round trip — see interest-tracing-hygiene.
  • Market exposure is briefly interrupted between sale and repurchase.
  • Repurchasing the same security within 30 days after a loss sale — the superficial-loss rule (ITA §54) denies the loss.
  • Co-mingling the re-borrowed funds before reinvesting, breaking the trace.
  • Underestimating the crystallized gain and creating a tax bill the investor must fund.

Trading costs, the tax on the crystallized gain, and any borrowing setup cost.

CRA’s deductibility test depends on what the borrowed money was used for. For a debt swap this requires the funds to be demonstrably used to purchase or replace an income-producing investment — a compliance-sensitive tracing requirement (sd-math/docs/strategy-notes/debt-swap.md). The repo note explicitly routes the question of whether the tool enforces or merely documents this to Risks.

unverified — needs Talbot — the suitability profile has not been established by SDC. Structurally it requires: a non-deductible balance, non-registered holdings with a manageable accrued gain, and a high enough marginal rate that the deduction is worth the crystallized tax.

  • Anyone whose non-registered holdings carry a large accrued gain — the immediate tax can exceed years of deduction benefit.
  • Anyone who cannot maintain the tracing documentation.
  • Anyone whose “investments” are inside an RRSP or TFSA — those cannot participate.

Not implementable from this record alone. The repo note flags open mechanics that a human financial-domain decision must settle first (below). Outline in principle:

  1. Quantify the accrued gain on the holdings to be sold.
  2. Sell, apply proceeds to the non-deductible debt.
  3. Re-borrow, and route proceeds directly into the investment account.
  4. Document the flow of funds.

design-note — ~/projects/monorepo/packages/sd-math/docs/strategy-notes/debt-swap.md, explicitly “Design note only, no code. Not implemented.” sd-math has no representation for a pre-existing non-deductible balance; everything modelled today is deductible investment debt from day one. No SDC numbers exist for this strategy.

  • Crystallizing a gain today to buy a deduction stream is a bet on the investor’s remaining horizon and future rates. Correct, and the record does not claim the trade is always favourable.
  • One-time conversion versus periodic conversion as equity becomes available. The repo note records this as undecided, and notes both variants need the same “time-varying loan balance” infrastructure the Smith Manoeuvre and LifeCycle notes also flag — solve once, not three times.
  • Whether the swapped debt is a mortgage specifically or any non-deductible personal debt: open.

The Market Drop Wins fold-in — decided 2026-09-22

Section titled “The Market Drop Wins fold-in — decided 2026-09-22”

Market Drop Wins listed the Debt Swap twice, as T0-9 Equity Debt Swap and T3-7 Debt Swap family. Neither becomes a new record. Both describe mechanisms this library already holds, and a decline-conditioned version of an existing mechanism is a variant, not a strategy.

The family, mapped once — this is the SSOT for the mapping:

Market Drop Wins memberThis library
Cash damming — cash-flow basedcash-damming (DS-2)
Classic — non-registered cash, no gains tollthis record (DS-1)
Equity — sell equity, repay, re-borrow; gains toll appliesthis record, as the equity variant below

Equity variant (T0-9), in full. Sell non-registered equity, repay non-deductible debt, re-borrow to repurchase. Total debt and total assets are unchanged; only deductibility changes — which is why the family sits at level 1 rather than 2. Its blocker in normal markets is the capital gains toll on the disposition, and a decline removes or shrinks that toll, which is the entire reason Market Drop Wins ranks it in Tier 0. Two conditions travel with it:

  • Superficial loss. Repurchase a similar but non-identical substitute; the rule bites only on identical property. The window is 61 days — 30 days either side of settlement.
  • The toll window is the opportunity, so this variant is amplified-by-decline even though the record as a whole is always.

⚠ Market Drop Wins labels the equity variant DS-3. That is its own numbering, not this library’s — DS-3 here is smith-manoeuvre. Do not import Market Drop Wins codes.

Source: market-drop-wins-library-v2 T0-9 and T3-7, and its Smart Debt Bridge table, which names the family as one of the bridges into Smart Debt; market-drop-wins-master-log-v2 §1.4 (the three family members), §8 (superficial-loss window).

smith-manoeuvre · cash-damming · interest-tracing-hygiene · better-rates-mortgage

  • ~/projects/monorepo/packages/sd-math/docs/strategy-notes/debt-swap.md — mechanism, gaps, and the three open questions
  • Core/_WorkingOn/Research/canada-investment-taxation.md §6.1–6.3 (purpose test), §3.7 (superficial loss), §9.2 (after-tax cost)
  • Core/_WorkingOn/Research/LevPublications/Leverage-Publications-Summaries.md — Robinson Smith names “debt swap” among the Smith Manoeuvre accelerators

Carried verbatim in substance from the repo note, all needing a human financial-domain decision:

  • Is the swapped debt a mortgage specifically, or any non-deductible personal debt?
  • One-time event or schedule-driven?
  • Does the math library enforce or merely document the interest-traceability requirement? A compliance-policy call, not a math one — routes to Risks.