10 December 1990 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
656960
Extra import data
{
"field_external_guid": [
"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1990 [DC90_029.031 - NV90_431.432]/DC90_199 — Approval of Self-directed RRSP"
],
"field_proprietary_citation": [],
"field_release_date_new": "1990-12-10 07:00:00",
"field_tags": []
}
Main text

December 10, 1990

Registered Plans Division          Financial Industries Division
Stella M. Kotlar, Director         D.S. Delorey
                                   957-3494

Attention: B.J. Greer

                                   7-902864

SUBJECT: Proposed Self Directed Registered Retirement Savings Plan ("RRSP")

This is in reply to your memorandum of October 12, 1990 concerning the 24(1) proposed self-directed RRSP submitted to the Department for approval.

Our files indicate that we have consistently taken the view (since at least 1974) that where the word "deposit" appears in the Act, it should be given the meaning it has within the particular trade or business involved. This view is reflected in the second paragraph of number 5 of IT-360R2 .

Where a bank is involved (e.g., where the "depositary" referred to in clause 146(1)(j)(ii)(C) of the Act is a bank), we have consistently maintained that a "deposit with a bank" is one that is shown on Schedule "J"; i.e., the "Consolidated Return of Assets and Liabilities" that a bank must file periodically with the Inspector General of Banks

          23             21(1)(b)

We therefore support your position that 24(1) proposed self-directed RRSP should not be approved.

          21(1)(b)            23

for Director Financial Industries Division Rulings Directorate