| 5-920330 | |||
| 24(1) | D. Duff | ||
| (613) 957-8953 |
Attention: 19(1)
April 7, 1992
Re: Part X.1 Tax
This is in response to your letter of January 27, 1992 requesting an opinion on the interpretation of the term undeducted RRSP premiums as defined in subsection 204.2(1.2) of the Income Tax Act ("Act"). Since your question deals with a proposed transaction it should be dealt with in a request for an advance income tax ruling, however, we can offer the following general comments.
We concur that an amount received in a year after 1990 by an individual from a registered retirement savings plan ("RRSP") or a registered retirement income fund ("RRIF") that is included in Part 1 income should be included in the amount referred to as J in subsection 204.2(1.2) of the Act to the extent that it exceeds any amount deducted pursuant to paragraph 60(l) of the Act in computing income for that year. Accordingly, in calculating the undeducted RRSP premiums pursuant to subsection 204.2(1.2) an amount received from a RRIF which is included in income and contributed to a spousal RRSP would be included in both I, a premium paid in the year, and J, an amount received out of a RRIF, such that they would cancel each other.
We trust our comments will be useful.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate