1 November 1990 External T.I. 901630 F - Admissibility of Foreign Currency Deposits for RRSP

By services, 18 January, 2022
Official title
Admissibility of Foreign Currency Deposits for RRSP
Language
French
CRA tags
146(1) retirement savings plan, 146(1)(j)(ii)(C), 205, 206(1) foreign property
Document number
Citation name
901630
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633792
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-11-01 07:00:00",
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Main text
24(1) 901630
  D. Duff
  (613) 957-3498

19(1)

November 1, 1990

19(1)

Re:  Registered Retirement Savings Plan (RRSP) Foreign Currency Deposit

This is in reply to your letter of July 19, 1990 requesting our opinion on whether depositary RRSPs conforming with clause 146(1)(j)(ii)(C) of the Income Tax Act (the "Act") can hold fixed-term deposits denominated in U.S. currency.

It is our view that paragraph 146(1)(g) of the Act and subsection 206(1) of the Act do not apply to a depositary RRSP since these provisions refer either to a trust governed by a RRSP or to other taxpayers listed in section 205 of the Act. Also, there are no provisions in clause 146(1)(j)(ii)(C) of the Act requiring such deposit arrangements to be held in Canadian denominated currency. Accordingly such plans would not be disqualified for holding fixed-term deposits denominated in U.S. currency.

We trust that these comments are satisfactory to you.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate