88 C.R. - Q.5

Where a Canadian resident rolls a lump sum payment received out of a U.S. pension fund into an individual retirement account the lump sum received by him is included in income pursuant to s. 56(1)(a)(i). If he is then permitted a deduction under s. 110(1)(f), payments received out of the IRA will be included in his income under s. 56(1)(a)(i).

If a Canadian resident is permitted under the Code to roll a lump sum payment received out of a U.S. pension fund into an IRA, a deduction in Canada will be permitted pursuant to s. 110(1)(f) to recognize the deferral permitted under Article XVIII of the U.S. Convention.