9 November 1989 Income Tax Severed Letter AC58510 - Allocations under DPSP - Meaning of "All Amounts"

By services, 22 July, 2022
Official title
Allocations under DPSP - Meaning of "All Amounts"
Language
English
Document number
Citation name
AC58510
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657620
Extra import data
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"field_proprietary_citation": [],
"field_release_date_new": "1989-11-09 07:00:00",
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Main text
19(1)                            5-8510
                                        A.B. Adler
                                        (613) 957-8962

November 9, 1989

Dear Sirs:

This is in reply to your letter of August 9, 1989 in which you requested our views regarding the meaning of "all amounts" used in paragraph 147(2)(i) of the Income Tax Act ("Act").

You indicated that    24(1)                                       
                                        Specifically, you are
concerned whether certain income amounts allocated to
beneficiaries of the Plan would be fully vested.

In our view the words "all amounts" used in paragraph 147(2)(i) of the Act would include all company contributions to and income amounts earned by the Plan that are allocated to a beneficiary thereunder. (The inclusion of income in amounts allocated to beneficiaries of the Plan is required under paragraph 147(2)(h) of the Act.) The extent to which income allocations vest in a beneficiary depends upon the relevant provisions of the registered Plan since paragraph 147(2)(i) sets a 5 year maximum, but no minimum, time limit for irrevocable vesting under deferred profit sharing plans.

We trust that our comments will be of assistance to you.

Yours truly,

for Director Financial Industries Division Rulings Directorate