Words and Phrases - "lump sum"

a
88
b
44
c
80
d
54
e
38
f
31
g
20
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
77
s
90
t
47
u
16
v
9
w
23
y
2

6 October 2006 Roundtable, 2006-0197091C6 F - Sens de série de paiements périodiques

Summary Under
Tax Topics - Income Tax Act - Section 60.01
successive partial IRA surrenders are excluded as “a series of periodic payments”

In order to maximize Canadian foreign tax credits for the U.S. tax withheld, a Canadian resident withdraws the amounts in the individual’s IRA through partial surrenders occurring over a number of years. Do these qualify as not being made as “part of a series of periodic payments”?

CRA responded:

Section 60.01 applies to a lump sum that is a one-time payment, which does not include each instalment that is made as part of a series of periodic payments to settle a particular lump sum.

Consequently … [such] payments … are part of a series of periodic payments and do not constitute an eligible amount within the meaning of section 60.01.

Words and Phrases
series of periodic payments periodic payment lump sum