XXXX R. Nanner (613) 957-8960
November 28, 1986
Dear Sirs:
Re: Withholding requirements in respect of an amended registered retirement savings plan ("RRSP")
This is in reply to your letter dated October 23, 1986 wherein you requested our comments on your understanding of the withholding requirements in respect of an "amended plan" within the meaning assigned to that expression in subsection 146(12) of the Income Tax Act (the "Act").
We confirm that:
(1) No amount is required to be withheld in the year of an amendment of an RRSP if no payment is made out of the plan in that year.
(2) A T4RSP supplementary is required to the date of the amendment for the amount that is required to be reported as income by the annuitant in accordance with paragraph 146(12)(b) of the Act.
(3) No withholding is required from any amount paid out subsequent to the year of the amendment.
(4) No T4RSP is required in the year of payment out of the plan for the amount that was reported on a T4RSP in the year of the amendment.
These opinions are our best interpretation of the law as it applies generally. They may, however, not always be appropriate in the circumstances of a particular case and, as stated in paragraph 24 of Information Circular 70-6R, they are not binding on this Department.
We trust our comments are of assistance to you.
Yours truly,
for Director Financial Industries Division Rulings Directorate Legislative and Intergovernmental Affairs Branch