| 24(1) | 5-901926 |
| D.S. Delorey | |
| (613) 957-3495 |
19(1)
November 6, 1990
This is in reply to your letter of August 13, 1990 concerning the comments in paragraph 7 of Interpretation Bulletin IT-412R.
It is our view that the transfer of property of a registered retirement savings plan from one trustee to another trustee pursuant to subsection 146(16) of the Income Tax Act (the "Act") does not constitute an acquisition of property by the trust for the purposes of paragraph 207.1(1)(b) of the Act. Thus, for the purposes of section 207.1 of the Act, the "grand-fathered" status of property acquired by the trust before August 25, 1972 will not be lost solely as i result of such transfer in and of itself.
The above comments are an expression of opinion only and are not binding on the Department, as explained in paragraph 21 of Information Circular 70-6R2. We trust however that they are of assistance to you.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate