| 19(1) | File No. 5-9560 |
| D. Duff | |
| (613) 957-3498 |
March 5, 1990
Re: 24(1)
This is in response to your letter of February 8, 1990 requesting the Department's opinion on the tax treatment of pension amounts contributed by 24(1) In particular, you asked if pension contributions made by these 24(1) would result in the application of paragraph 146(5)(a) of the Income Tax Act (the Act) regarding contributions to a Registered retirement savings plan (RRSP).
As discussed by telephone on February 26, 1990 19(1) Duff) pension contributions made by 24(1) In addition employer contributions are required to pay for the pensions provided by this plan. Therefore RRSP contributions by these 24(1) will be limited by the provisions in paragraph 146(5)(a) of the Act. The 24(1) contributions, regardless of how they are allocated within the plan, are contributions to a Registered Pension Plan and deductible under paragraph 8(1)(m) of the Act.
We trust these comments will be of assistance to you.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate