27 September 1990 Ministerial Correspondence 901544 F - Canada-U.K. Income Tax Convention on Pension

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.

This is in reply to your letter dated July 9, 1990 whereby you enquired concerning a pension paid to you by  24(1) 

We do not have sufficient information to permit us to express a definitive opinion.  However, based on the information set forth in your letter, 24(1)  Deductions for pension contributions are generally only available for contributions to pension plans registered under the Income Tax Act (Canada).  Also the payment does not appear to constitute a foreign tax and thus would not be eligible for the deduction available in respect of certain foreign taxes.

A resident of Canada is taxable on his world-wide income from all sources and thus you are taxable in respect of the pension payments received by you from the United Kingdom.  However, the United Kingdom pension may be eligible for the pension credit available to certain individuals in respect of up to $1,000 of pension income. Of course, if you have other eligible pension income (excluding, among other payments, payments from the Canada Pension Plan and Old Age Security pension payments) of a t least $1,000, this pension credit will have no practical application to your United Kingdom pension.

If you require any further assistance in respect of this matter, we recommend that you contact your local district taxation office at 150 Main Street West, Hamilton, Ontario, K8N 2S3, Telephone No. 522-8671 or 1-800-263-9200 or 1-800-263-9210.

Yours truly,

for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch