25 January 1990 Internal T.I. 59277 F - Canada-U.K. Income Tax Convention - Lump Sum Withdrawal from RRSP

By services, 18 January, 2022
Official title
Canada-U.K. Income Tax Convention - Lump Sum Withdrawal from RRSP
Language
French
CRA tags
n/a
Document number
Citation name
59277
Severed letter type
Technical Interpretation - Internal
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
629880
Extra import data
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Main text
19(1) File No. 5-9277
  D. Duff
  (613) 957-3498

January 25, 1990

Dear Sirs:

This is in reply to your letter of December 15, 1989, wherein you requested our interpretation of whether or not a lump sum withdrawal from a Registered Retirement Savings Plan (RRSP) by a United Kingdom resident would be exempt from tax in Canada pursuant to Article XVII of the Canada-U.K. Tax Convention.

It is our position that a full or partial lump sum withdrawal from a RRSP would not be considered a pension for purposes of Article XVII(1) of the Canada-U.K. Tax Convention and, consequently, would not be exempt from tax in Canada pursuant to that Article.

We trust our comments will be of assistance to you.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate