30 November 1995 Ruling 9613993 - RRSP XXXXXXXXXX

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.

Principal Issues:

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Position:

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Reasons:

In accordance with ATR-24

XXXXXXXXXX                                      3-961399
XXXXXXXXXX

Attention: XXXXXXXXXX

XXXXXXXXXX, 1996

Dear Sirs:

Re: Advance Income Tax Ruling
XXXXXXXXXX
Deferred Profit Sharing Plan
Group Registered Retirement Savings Plan
Group Pension Plan XXXXXXXXXX

We are writing in reply to your letter of XXXXXXXXXX, as supplemented by your letters of XXXXXXXXXX and numerous telephone conversations wherein you requested certain advance income tax rulings (the "Rulings") on behalf of XXXXXXXXXX.

You have advised us that to the best of XXXXXXXXXX knowledge none of the issues involved herein are being considered by a Tax Services Office or Taxation Centre of Revenue Canada in connection with a tax return already filed and that none of the issues are under objection or appeal.

Our understanding of the facts and proposed transactions is as follows:

FACTS

1. XXXXXXXXXX is a corporation incorporated under the Canada Business Corporations Act.

XXXXXXXXXX

2. a. XXXXXXXXXX. This plan constituted a deferred profit sharing plan (the "DPSP") as that term is defined under the Income Tax Act (Canada) (the "Act").

b. XXXXXXXXXX. The terms of the DPSP provided for both employer and employee contributions.

3. a.

XXXXXXXXXX

b. XXXXXXXXXX

c. The interest rate applicable to the XXXXXXXXXX was established by

XXXXXXXXXX

4. a.

XXXXXXXXXX

b. XXXXXXXXXX amended the DPSP to prohibit employee contributions to the DPSP and to provide that employer contributions to the DPSP would be calculated as a percentage of an employee's contribution to the Group RRSP (subject to prescribed limits). These changes were made in order to comply with amendments to the Act prohibiting employee contributions to a DPSP.

c. The funds in the Group RRSP were applicable to the same investment options as those described above at paragraph 3 for funds in the DPSP.

5. XXXXXXXXXX

6. a.

XXXXXXXXXX

b. XXXXXXXXXX

c. XXXXXXXXXX

d. XXXXXXXXXX

e. XXXXXXXXXX

f. XXXXXXXXXX

7. XXXXXXXXXX

8. XXXXXXXXXX

9. a.

XXXXXXXXXX

b. XXXXXXXXXX

c. XXXXXXXXXX

d. XXXXXXXXXX

e. XXXXXXXXXX

10. XXXXXXXXXX

11. XXXXXXXXXX

12. XXXXXXXXXX

13. XXXXXXXXXX

14. XXXXXXXXXX

PROPOSED TRANSACTIONS

15. XXXXXXXXXX

16. XXXXXXXXXX

17. XXXXXXXXXX

18. XXXXXXXXXX

19. XXXXXXXXXX

20. XXXXXXXXXX

21. XXXXXXXXXX

PURPOSE OF PROPOSED TRANSACTIONS

22. The purpose of the proposed transactions is to avoid

XXXXXXXXXX

RULINGS GIVEN

Provided that the above statement of facts and proposed transactions are accurate and constitute complete disclosure of all relevant facts and proposed transactions and the proposed transactions are carried out as described above, our Rulings are as follows:

A. XXXXXXXXXX

B. XXXXXXXXXX

The above rulings are given subject to the general limitations and qualifications set out in Information Circular 70-6R2 dated September 28, 1990, as amended by Special Release dated September 30, 1992, issued by Revenue Canada and are binding provided that the proposed assignment agreement is entered into and is effective on or before XXXXXXXXXX.

These rulings are based on the Act and the Regulations as of the date of this ruling letter without taking into account any future amendments thereto, whether currently proposed or not.

Yours truly,

for Director
Financial Industries Division
Income Tax Rulings and
Interpretations Directorate