25 January 1990 Income Tax Severed Letter AC594455 - Canada-U.K. Income Tax Convention - Lump Sum Withdrawal from RRSP

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.

5-9445
                                                  D. Duff
                                                  (613) 957-3498

January 25, 1990

Dear Sirs:

This is in reply to the letter of April 7, 1989, from 19(1) of your office, and further to our interim letter of August 8, 1989, concerning the application of Article XVII of the Canada-U.K. Tax Convention to lump sum withdrawals from a Registered Retirement Savings Plan (RRSP).

As discussed by telephone on January 23, 1990 (19(1)/Duff) it is our position that a full or partial lump sum withdrawal from a RRSP would not be considered a pension for purposes of Article XVII(1) of the Canada-U.K. Tax Convention and, consequently, would not be exempt from tax in Canada pursuant to that Article.

We trust our comments will be of assistance to you.

Yours truly,

for Director Financial Industries Division Rulings Directorate