19(1)
900324
A.B. Adler
(613) 957-8962April 20, 1990
19(1)
This is in reply to your letter of April 3, 1990 in which you requested our views regarding the maximum amount in respect of a retiring allowance that you would be permitted to transfer directly to an RRSP upon you resignation from employment, effective June 29, 1990.
For your information, as indicated in paragraph 23 of Information Circular No. IC 70-6R (copy enclosed), we do not provide written opinions for proposed transactions. Should you require an advance ruling paragraphs 15 and 16 therein outline the procedure for requesting such rulings. However, we are prepared to provide you with the following general comments.
The Department has previously determined that amounts received in lieu of an fulfilled surplus period under article 10 of the Work Force Adjustment Policy of Treasury Board will generally qualify as a retiring allowance for the purposes of the Income Tax Act. It should be noted however, that any reimbursement to the Receiver General as a result of a reappointment to the Public Service is not deductible under the provisions of the Income Tax Act.
Furthermore, based on the information attached to your letter, we noted no errors in your conclusions concerning the maximum amount transferable to an RRSP.
We trust that our comments will be of assistance to you.
Yours truly, for Director Financial Industries Division Rulings Directorate