| 19(1) | File No. 5-9741 |
| A.B. Adler | |
| (613) 957-8962 |
March 23, 1990
Dear Sirs:
This is in reply to your letter dated March 2, 1990 in which you requested our views with respect to the application of subparagraph 8(1)(m)(ii) and subsection 8(7) of the Income Tax Act ("Act").
As indicated in paragraph 23 of Information Circular No. 70-6R we do provide written opinions on proposed transactions. However, we are prepared to provide you with our general comments.
Under existing legislation, it is our view that, in addition to the current service deduction that a teacher may claim under subparagraph 8(1)(m)(i) and 8(1) (m.1), the teacher may also claim a deduction under subparagraph 8(1)(m)(ii) of the Act of up to $3500 for a contribution to an RPP in respect of past services for a year regardless of whether the teacher was a contributor to the RPP in that previous year.
We trust that our comments will be of assistance to you.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate