Interesting problem. 

A man contributes $100,000 to a spousal rrsp for his wife (he has moved to a higher tax bracket, and has accumulated $100,000 in contribution room). He has paid over $70,000 in income taxes in 2016, and now expects to generate a $50,000 refund from the deduction.
The wife historically handles the investing. The CRA allows the contribution, but NOT THE DEDUCTION on the basis that she is carrying on an investment business  (she handles their investments outside the rrsp, does not work in the financial industry, and has been permitted to declare capital gains and dividends in the past, without problem).

 This seems impossible for a variety of reasons, but the CRA's logic is that if somebody does something with a reasonable expectation of profit, then that person is carrying on a business in the eyes of the CRA. The amount of time spent investing is a major factor. The courts have held the CRA's position, but not with respect to rrsps (prochuk v queen 2014).

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