13 October 1989 Ruling 74333 F - Form T746

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.

Subject: Form T746 Rev.89

In accordance with the request (T782) of September 29,1989 we have reviewed the above-noted form.

Our comments in the attached appendix are based on the provisions of the Income Tax Act as proposed to be amended by Bill C-28 (first reading, June 20, 1989) and the draft Notice of Ways and Means Motion dated 13-9-89 dealing with pension reform.  Unless otherwise indicated, the references to sections, subsections, etc., are to the Income Tax Act.

If you have any questions, please contact us.

A.G. CockellDirectorTechnical Interpretations Division Legislative and Intergovernmental Affairs Branch

Form T746 Rev.89

AREA I

1. Line(1).

     In the bracketed statement replace "direct transfers between RRSPs" with "direct transfers to RRSPs"

     The suggested change is intended to reflect direct transfers from RPPs, DPSPs and RRSPs under subsections 147.3(1) and (4) to(7), 147(19) and 146(16), respectively.  The present statement appears to only reflect subsection 146(16).

2. Line (2).

     The descriptions of lines (1), (2) and(4) refer to "transfers", but the meaning to be attached to such word differs depending on the context it is used (i.e., transfers that involve both an income inclusion and deduction and transfers that do not). This may be confusing to a reader.

3. Lines(2) to (5).

     In order to simplify the form, could lines (2) and (3) and lines (4) and (5) be combined?  If they are combined, the comment below line (7) concerning the application of Part X.l tax would require rewording.

AREA II

4. Line (8).

     The reference to refunds received in the year following certification of refundable excess contributions of form T3012 appears to be misleading since the refunds received in 1989 (to be reported on line(8)) may have been "certified", for example, in 1989. In this case, line (8) incorrectly instructs a taxpayer to disclose the refunds in completing the T746 for 1990, not 1989, notwithstanding the related excess RRSP contributions may have been made in 1987.

     In addition, where the amount in box(E) is also part of the amount in box(F) of the T4RSP slip, which may occur according to the back printing on the slip, the amount in line (11) will be overstated.