In order to maximize Canadian foreign tax credits for the U.S. tax withheld, a Canadian resident withdraws the amounts in the individual’s IRA through partial surrenders occurring over a number of years. Do these qualify as not being made as “part of a series of periodic payments”?
CRA responded:
Section 60.01 applies to a lump sum that is a one-time payment, which does not include each instalment that is made as part of a series of periodic payments to settle a particular lump sum.
Consequently … [such] payments … are part of a series of periodic payments and do not constitute an eligible amount within the meaning of section 60.01.