Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.
Principal Issues: Whether RPP can be registered permitting past-service contributions.
Position: Cannot rule.
Reasons: Both a registrations matter and a question of fact and completed transaction (employment status in past).
XXXXXXXXXX 2000-001622
Attention: XXXXXXXXXX
March 27, 2000
Dear Sirs:
RE: Proposed Individual Plan Registration
XXXXXXXXXX (the "Corporation")
This is in reply to your letter of February 28, 2000, and further to our telephone conversation (Spice/XXXXXXXXXX) of March 24, 2000 concerning your request for an advance income tax ruling on behalf of the above-noted taxpayer.
As advised in the conversation your request concerns the status of certain individuals vis à-vis the Corporation during the 1991 through 1999 taxation years and an income tax ruling is not available in these circumstances. As we indicated in our letter of December 1, 1999 (our file 992951) it is not possible for the Canada Customs and Revenue Agency to confirm whether an employee/employer relationship existed in the years in question from the information submitted. Whether a registered pension plan can be registered which permits past-service contributions in respect of these years must be determined in some other way and we suggest you contact the Registered Plans Division to pursue your enquiry.
We will therefore close our file and your deposit will be returned under separate cover.
Yours truly,
Patricia Spice
for Director
Financial Industries Division
Income Tax Rulings Directorate