25 January 1990 External T.I. 59445 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
59445
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
631805
Extra import data
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"field_release_date_new": "1990-01-25 07:00:00",
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Main text
19(1) File No. 5-9445
  D. Duff
  (613) 957-3498

January 25, 1990

Dear Sirs:

This is in reply to the letter of April 7, 1989, from 19(1) of your office, and further to our interim letter of August 8, 1989, concerning the application of Article XVII of the Canada-U.K. Tax Convention to lump sum withdrawals from a Registered Retirement Savings Plan (RRSP).

As discussed by telephone on January 23, 1990 (19(1)/Duff) 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