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I am running the Smith Manoevre and have claimed opening/appraisal fees on line 22100. I have not been audited/bothered about it by the CRA.

If you go to the source:

Claim the following carrying charges and interest that you paid to earn income from investments:
  • fees to manage or take care of your investments
Appraisal fee was necessary to open the HELOC which is being used to take care of your investments.
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