XXXX
41471 D. Evanson (613) 957-3498
Attention: XXXX
March 1st, 1989
Dear Sirs/Mesdames:
Re: XXXX Registered Pension Plan
We are writing in reply to your letter of January 4, 1989 and further to our telephone conversation (Evanson XXXX) of February 4, 1989, regarding the application of Part XI of the Income Tax Act (the "Act").
In our opinion the provisions of section 206 of the Act restricting the ownership of foreign property by a registered pension plan are applicable to all funds governed by the plan. It would therefore be in order to combine the assets of the deposit administration policy with the assets held by the trust company in determining the percentage of foreign property held. For this purpose, it is not necessary that the deposit administration policy be assigned or transferred to the trust company.
We trust that the foregoing will be of assistance to you.
Yours truly,
for Director Financial Industries Division Rulings Directorate