| 19(1) | File No. 5-8477 |
| F. Francis | |
| (613) 957-3496 |
November 3, 1989
Dear Sir:
This is in reply to your letter of August 4, 1989, wherein you requested our opinion as to whether a withdrawal of amounts under a registered retirement savings plan ("RRSP") by a resident of Australia would be subject to a lower treaty rate for pensions and annuities under the Canada-Australia Income Tax Convention (1980) or the higher 25% withholding tax.
It is our opinion that a lump sum payment under an RRSP would not be considered as a pension payment and would therefore be subject to 25% tax under subsection 212(1)(i) of the Income Tax Act.
We trust the above comments will be of assistance to you.
Yours truly,
Wayne Douglasfor DirectorFinancial Industries DivisionRulings Directorate