5-911715
Dear 19(1)
Re: Deferred Income Plans — Foreign Currency
This is in reply to your letter of June 18, 1991 regarding the situation where a trust governed by a deferred income plan acquires foreign currency pursuant to the deeming provisions of paragraph 259(1)(b) of the Income Tax Act (the "Act").
In our letter of June 13, 1991, we stated that, where a trust governed by a registered retirement savings plan acquired foreign currency as part of a transaction with a qualified investment denominated in foreign currency, it was the Department's position that the foreign currency would not be considered to be a non-qualified investment providing that it was converted to a qualified investment within a reasonable time.
This was an administrative position that has not been extended to include the situation when the plan is deemed to acquire the foreign currency pursuant to paragraph 259(1)(b) of the Act.
We trust this is satisfactory.
Yours truly,
for Director Financial Industries DivisionRulings Directorate
cc: Don Wyse Lyne Aubin-Morisset