13 October 1989 Income Tax Severed Letter AC74333 - Form T746

October 13, 1989

P. McNally, Director                  Technical Interpretations 
Enquiries and Taxpayer Assistance      Division
 Division                             S. Parnanzone
                                      957-9232

Rick Oven

7-4333 Form T746 Rev.89

In accordance with the request (T782) of September 29,1989 we have reviewed the above-noted form.

Our comments in the attached appendix are based on the provisions of the Income Tax Act as proposed to be amended by Bill C-28 (first reading, June 20, 1989) and the draft Notice of Ways and Means Motion dated 13-9-89 dealing with pension reform. Unless otherwise indicated, the references to sections, subsections, etc., are to the Income Tax Act.

If you have any questions, please contact us.

 Director
 Technical Interpretations Division
 Legislative and Intergovernmental
   Affairs Branch
                                                    Appendix
                                                    S. Parnanzone
                                                    957-9232

                                  Form T746
                                   Rev.89
AREA I

1. Line(1).

            In the bracketed statement replace "direct transfers 
            between RRSPs" with "direct transfers to RRSPs"
            The suggested change is intended to reflect direct   
            transfers from RPPs, DPSPs and RRSPs under
            subsections 147.3(1) and (4) to(7), 147(19) and
            146(16), respectively.  The present statement appears
            to only reflect subsection 146(16).

2. one (2).

            The descriptions of lines (1), (2) and(4) refer to   
            "transfers", but the meaning to be attached to such  
            word differs depending on the context it is used
            (i.e., transfers that involve both an income
            inclusion and deduction and transfers that do not).
            This may be confusing to a reader.

3. Lines(2) to (5).

            In order to simplify the form, could lines (2) and
            (3) and lines (4) and (5) be combined?  If they are
            combined, the comment below line (7) concerning the  
            application of Part X.l tax would require rewording.
AREA II

4. Line (8).

            The reference to refunds received in the year
            following certification of refundable excess
            contributions of form T3012 appears to be misleading
            since the refunds received in 1989 (to be reported on
            line(8)) may have been "certified", for example, in
            1989. In this case, line (8) incorrectly instructs a
            taxpayer to disclose the refunds in completing the
            T746 for 1990, not 1989, notwithstanding the related
            excess RRSP contributions may have been made in 1987.

            In addition, where the amount in box(E) is also part
            of the amount in box(F) of the T4RSP slip, which may
            occur according to the back printing on the slip, the
            amount in line (11) will be overstated.