Regarding the deductibility of foreign tax paid on non-business income in computing income for purposes of the Part XI.3 tax on retirement compensation arrangements, CRA stated:
Subsection 207.7(1) requires an RCA trust to pay, for each taxation year of the trust, a refundable tax under Part XI.3 of the Act equal to the amount calculated under that subsection. For this purpose, the trust must include, inter alia, income from a property (determined without reference to paragraph 82(1)(b).) The computation of this income from property must be made in accordance with the provisions of Part I. For this purpose, the foreign tax deductions in subsections 20(11) and 20(12) may be applicable depending on the circumstances.