MAY 12 1987
TO: TORONTO DISTRICT OFFICE
FROM: SPECIALTY RULINGS DIRECTORATE Farms, Personal and General Section N.M. Sheerin (613) 957-2135
Attention: Naomi Tsuji
Section 148-14
Business Enquiries Group
RE: XXXX
Whether Bridging Supplement Qualifies as a
"Retiring Allowance"
This is in reply to your memorandum of March 23, 1987, in which you enquired whether the bridging supplement received by XXXX is to be considered a retiring allowance or pension income.
Based on the information you submitted, it is our opinion that the bridging supplement payments received by these taxpayers qualify as a retiring allowance provided they are not paid out of a superannuation or pension fund or plan. The maximum amount eligible for rollover to a registered retirement savings plan would be determined by applying the formula contained in paragraph 60(j.1) to:
a) the lump sum retirement allowance received by the taxpayers at the time of their retirement (and described in paragraph 2 of their termination letter), and
b) the total supplementary benefits to be received to age 65.
We trust these comments will be of assistance to you.
ORIGINAL SIGNED BY
for Director
Small Business and General Division
Specialty Rulings Directorate
Legislative and Intergovernmental
Affairs Branch