31 July 2002 Internal T.I. 2002-0136937 F - Placement Français "Assurance-salaire-vie -- summary under Article 18

The holder in France of an "assurance-salaire-vie," which is similar to a registered retirement savings plan except that a withdrawal from it is taxable only if made within the first eight years of the contribution, immigrates to Canada. The Directorate indicated that it was unlikely that withdrawals from the plan would be exempted under Art. XVIII(1) of the France-Canada Convention as a “pension” as the only contributions were employee contributions, nor would they qualify as an :annuity” per Art. XVIII(3). Under Art. XXI of the Convention, the withdrawals could be taxed in Canada, and also in France.