28 February 1991 Income Tax Severed Letter

By services, 22 July, 2022
Language
English
Document number
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656257
Extra import data
{
"field_external_guid": [
"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1991 [MR91_194.197 - FE91_224.226]/FE91_014 — RRSP Contributions - 1991 and Subsequent Years"
],
"field_proprietary_citation": [],
"field_release_date_new": "1991-02-28 07:00:00",
"field_tags": []
}
Main text
24(1)                         5-910460
                                        P. Spice
                                        (613) 957-8953
               19(1)

February 28, 1991

Dear Sirs:

Re: RRSP Contributions 1991 and Subsequent Years

Your letter of February 11, 1991, to Technical and Intergovernmental Affairs has been referred to us for reply. You asked whether a person who was a non-resident in 1990 can contribute to an RRSP for 1991.

The legislation permits an RRSP contribution in 1991 no greater than the amount of the taxpayer's "RRSP deduction limit" as defined in paragraph 146(1)(g.1). Because this definition refers to the lesser of the "RRSP dollar limit" (11,500 for 1991) and the taxpayer's earned income is relevant for purposes of determining a taxpayer's 1991 contribution limit.

Based on the facts of the two scenarios you describe neither the returning taxpayers nor the immigrant taxpayers have 1990 "earned income" (defined in paragraph 146(1)(c)) and therefore are not able to contribute in 1991. Generally speaking, earned income includes only taxable Canadian income.

We trust these comments are of assistance to you.

Your truly,

for Director Financial Industries Division Filings Directorate

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