31 October 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
657092
Extra import data
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"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1990 [NV90_433 - OC90_200.201]/OC90_014 — Allocation of Forfeited Amounts under DPSP and Calculation of Deductible RRSP Contribution"
],
"field_proprietary_citation": [],
"field_release_date_new": "1990-10-31 07:00:00",
"field_tags": []
}
Main text
24(1)
                                             902435
                                             M. Shea-DesRosiers
                                             (613) 957-8953
          19(1)

October 31, 1990

Dear Sirs:

Re: Paragraph 147(2) (i.1) of the Income Tax Act (the "Act") - Deferred Profit Sharing Plan ("DPSP") - Registered Retirement Savings Plan ("RRSP")

This is in reply to your letter of September 5, 1990 wherein you request a technical interpretation concerning the application of subsection 146(5) to the 1990 calendar year.

We generally do not provide written opinions with respect to actual and completed transactions, however, we are prepared to provide you with the following general comments.

In a situation where the corporate employer does not make a DPSP contribution because it incurred a loss in the year and the terms of the DPSP as registered require the allocation of forfeited amounts to the beneficiaries of the plan, it is our view that such an allocation would not, in and by itself, require the employee to calculate his/her deductibLe RRSP contribution for 1990 under paragraph 146(5)(a) of the Act.

We trust the above comments will be of assistance to you.

Yours truly,

for Director Financial Industries Division Rulings Directorate