2 April 1998 External T.I. 9802535 - NRTA1, NO SIN

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:

Will we accept an NRTA1 without the applicant having a SIN?

Position: N/A

Reasons:

Forms Processing Division has advised us that there are situations where we will accept the form without a SIN and the Registered Plans Division has advised us that there are situations where they will register an RRSP when the applicant does not have a SIN so we have directed the author to the appropriate area in respect of any particular situation that may arise.

980253
XXXXXXXXXX M.P. Sarazin

Attention: XXXXXXXXXX

April 2, 1998

Dear Sirs:

Re: Form NRTA1 and the Social Insurance Number Requirement

This is in reply to your facsimile dated February 2, 1998, wherein you requested confirmation that a non-resident surviving spouse of a deceased Canadian who had an unmatured registered retirement savings plan (“RRSP”) on death could file a form NRTA1 without a social insurance number in respect of the transfer of a refund of premiums to a new RRSP set-up for the surviving spouse. You advise that the surviving spouse will apply for a social insurance number in accordance with subsection 237(1) of the Income Tax Act.

Comments

The determination of whether a form will be accepted or an RRSP registered without a social insurance number is not the responsibility of the Income Tax Rulings & Interpretations Directorate. However, we have confirmed with our Assessing Division and Registered Plans Division that there are situations where a NRTA1 may be accepted and an RRSP may be registered without a taxpayer having a social insurance number. Any questions in respect of the procedures that have to be followed in order to register an RRSP without a social insurance number should be directed to the Registered Plans Division at (613) 954-0419. Once the taxpayer has an RRSP, the form NRTA1 should be completed and forwarded to the Transferor. In order to ensure that the Transferee and the Transferor comply with the NRTA1 (completed without a social insurance number), we suggest that you request the local tax services office’s confirmation that it will accept the NRTA1 before it is forwarded to the Transferee.

We trust that the above comments will be of assistance to you.

Yours truly,

Paul Lynch
for Director
Financial Industries Division
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch