7-910787
"Earned income" as defined in paragraph 146(1)(c) of the Income Tax Act (the "Act")
This is in reply to your memorandum of December 27, 1990 and further to our telephone conversation (Murray/Shea-DesRosiers) of April 3, 1991 concerning the above-mentioned subject.
21(1)(b)
Therefore, our position remains the same as it was prior to 1988; that is, the income and loss arising from the rental of real property that a partner derives from a limited partnership must be taken into account when calculating "earned income" for the purposes of an RRSP.
Note also that such income and losses are required to be reported by the partnership to the partners in box B of the T5013 supplementary and that such amounts are included in the partner's T1 at line 126 (Rental income) as opposed to line 122 (Partnership income).
We trust the above comments will be of assistance to you.
ChiefDeferred Income Plans and Trusts SectionFinancial Industries DivisionRulings Directorate