8 July 1991 External T.I. 911230 F - Transfer From Employee Benefit Plan (EBP) to RPP

By services, 18 January, 2022
Official title
Transfer From Employee Benefit Plan (EBP) to RPP
Language
French
CRA tags
6(1)(g)
Document number
Citation name
911230
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
632670
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1991-07-08 08:00:00",
"field_tags": []
}
Main text

24(1)

Your letter of February 8, 1991, to the Registered Plans Division, Revenue Canada Taxation, has been forwarded to us for reply.

24(1)

There is no provision in the Income Tax Act (the "Act") permitting such a transfer either at the employer or employee level.  From the description of the U.S. plan it appears to be an Employee Benefit Plan ("EBP"), as defined in section 248 of the Act.  Amounts received from EBPs are taxable pursuant to paragraph 6(1)(g) and there is no provision for transferring such amounts to a RPP or any other deferred income plan.

We trust our comments are satisfactory and we apologize for the delay in responding to your letter.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate