26 November 1993 Income Tax Severed Letter 9331525 - NISA

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.

Mr. Mitch A. Davies
Chief
Policy and Planning
NISA Administration
Winnipeg, Manitoba                         933152
R3C 3A4

November 26, 1993

Dear Mr. Davies:

Re: Net Income Stabilization Account (NISA) - Adjustments

This is in reply to your letter of October 26, 1993 concerning the issue of adjustments to Fund 2 in a scenario where, for example, in 1992 funds were incorrectly transferred as a deemed withdrawal from the participant's Fund 2 to his Fund 1. The transfer was included in the taxable income stated on the participant's 1992 NISA Annual Account Statement. In 1993, the error was brought to your attention and a corrective adjustment was made.

You ask which taxation year should reflect such an adjustment and then go on to say that in your view, since the deemed withdrawal transaction was reversed, the taxable benefit reportable for 1992 should also be negated. An amended T5 will be issued for the affected year.

We agree with your view. It is the 1992 taxation year figures that are incorrect and it is the 1992 taxation year figures that should be corrected to reflect the accurate taxable income which, of course, will be subject to the taxation rates for that year.

We trust our comments will be of assistance to you.

Yours truly,

Roberta Albert for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch