5-901857
This is in response to your letter of August 1, 1990 regarding the transfer of a retiring allowance to a registered retirement savings plan ("RRSP").
The Department does not give opinions on proposed transactions, other than in the form of an advanced income tax rulings, however, we offer the following comments.
Paragraph 60(j.1) of the Income Tax Act (the "Act") permits such a transfer to a maximum of $2,000 times the number of years employed (plus $1,500 for each of these years before 1989) for which employer contributions to a pension plan or deferred profit saving plan have not vested in the employee.
There is no requirement that such employment must be continuous. Furthermore, it is the Department's position that a part of a calendar year can be considered as a full year.
We trust that these comments are satisfactory to you.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate