| 24(1) | 902435 |
| Maureen Shea-DesRosierss | |
| (613) 957-8953 | |
| 19(1) |
October 31, 1990
Dear Sirs:
Re: Paragraph 147(2)(i.1) of the Income Tax Act (the "Act") - Deferred Profit Sharing Plan ("DPSP") - Registered Retirement Savings Plan ("RRSP")
This is in reply to your letter of September 5, 1990 wherein you request a technical interpretation concerning the application of subsection 146(5) to the 1990 calendar year.
We generally do not provide written opinions with respect to actual and completed transactions, however, we are prepared to provide you with the following general comments.
In a situation where the corporate employer does not make a DPSP contribution because it incurred a loss in the year and the terms of the DPSP as registered require the allocation of forfeited amounts to the beneficiaries of the plan, it is our view that such an allocation would not, in and by itself, require the employee to calculate his/her deductible RRSP contribution for 1990 under paragraph 146(5)(a) of the Act.
We trust the above comments will be of assistance to you.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate