20 January 1992 Income Tax Severed Letter 197

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

Subject: RRSP ADMINISTRATIVE FEES Section(s): 146(5), 18(1)(a)]

• 5- 912968 D. Duff (613) 957-8953

XXX

Attention: XXX

January 20, 1992

Re: Administrative Fees on registered retirement savings plans (“RRSPs”)

This is in response to your letter of October 22, 1991 requesting our opinion on the treatment of administration fees paid to the trustee by the annuitant of a RRSP.

You specifically asked that, where an annuitant has the option of paying the administration fees directly to the trustee or by a payment into the RRSP account which is subsequently used to pay the fees, would such a payment into the RRSp account be considered a contribution to a RRSP for which a receipt should be issued. It is our position that such a payment into the RRSP account is a contribution to a RRSP regardless if it is intended to cover administration fees charged by the trustee. As such a receipt for a contribution to a RRSP should be issued.

As stated in paragraph 2 of Interpretation Bulletin IT-124R5 and on page 41 of the 1991 Pension and RRSP Tax Guide, reasonable administration fees paid to the trustee of the RRSP can be deducted from income. Also, as stated on page 41 of the aforementioned Guide, administration fees paid from the RRSP funds are not deductible to the annuitant, consequently, fees paid through the RRSP for which a receipt has been issued can be treated by the annuitant as a contribution to a RRSP but not as an administration fee.

We trust our comments are of assistance.

Yours truly,

for Director
Financial Industries Division
Rulings Directorate