S. 922 of the Taxation Act (Quebec) provided that “an individual may deduct, in computing his income for a taxation year, the amount that, by virtue of [ITA s. 146(5)], is allowed as a deduction for the year in computing his income for the purposes of the said Act.” An individual deducted a premium paid to his RRSP for the year form Quebec but not federal purposes. Did this amount qualify as having been allowed as a deduction federally?
CRA stated:
[I]f a taxpayer does not claim a deduction by virtue of subsection 146(5) in computing the taxpayer’s income for a taxation year, the deduction amount under that subsection for that taxation year will be nil.