18 July 1988 Income Tax Severed Letter 7-2092 - []

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.

DATE JUL 18 1988

TO H. Robinson E & OE Halifax D.O.

FROM Specialty. Rulings Directorate K.B. Harding (613) 957-2129

SUBJECT XXXX

This is in reply to your round trip memorandum dated September 9, 1987 requesting our opinion whether the above taxpayer, who ceased to reside in the United States and became a resident of Canada, would be permitted to roll amounts received from an IRA to a RRSP.

We have recently completed our review of the Canadian tax treatment of amounts received out of U.S. retirement plans and are enclosing a general statement of our position on this matter.

Since you have not provided us with enough details to determine the exact nature of the IRA we cannot respond to your specific request. However, the attached general statement should indicate what information is required from the above taxpayer in order to determine his tax treatment on the receipt of payment from his IRA.

If you have any questions please call Mr. Harding at (613) 957-2129.

for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs-Branch

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