Section 207.5

Subsection 207.5(1) - Definitions

Advantage

Administrative Policy

29 October 2013 External T.I. 2013-0501941E5 - RCA transitional rule

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5 October 2012 Roundtable, 2012-0453141C6 F - RCA, prohibited investment

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Articles

Jillian Welch, "Retirement Compensation Arrangements: an Update on the Advantage Rule", Taxation of Executive Compensation and Retirement Special Pension Edition, Volume XVII, No. 3, 2013, p. 1074.

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Paragraph (a)

Administrative Policy

16 September 2016 Internal T.I. 2013-0500581I7 - RCA advantage tax rules

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.62 - Subsection 207.62(2) - Paragraph 207.62(2)(a) FMV of pledging benefit equal to PV of interest savings 98

14 December 2015 External T.I. 2013-0499501E5 - RCA advantages-Life insurance policy held by an RCA

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14 December 2015 External T.I. 2014-0544211E5 - RCA advs - Life insurance policy held by an RCA

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17 May 2013 Roundtable, 2013-0481421C6 - Transfer of life insurance policy to a retiree

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RCA Strip

Administrative Policy

15 May 2017 External T.I. 2015-0580461E5 F - Life insurance policy held in an RCA trust

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.5 - Subsection 207.5(3) s. 207.7(2) refund might be generated where an RCA trust distributes a life insurance policy to its employee beneficiary 326

Refundable Tax

Administrative Policy

12 January 2015 External T.I. 2013-0511051E5 - Employer loan to RCA

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12 March 1996 TI 953128

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28 June 1995 Internal T.I. 7-950849 -

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92 C.R. - Q.49

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88 C.R. - Q.30

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.6 - Subsection 207.6(2) 30

Articles

Jim Kahane, Uros Karadzic, Simon Létourneau-Laroche, "A Fresh Look at Retirement Compensation Arrangement: A Flexible Vehicle for Retirement Planning", Canadian Tax Journal (2013) 61:2, 479 – 502.

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Manjit Singh, Jillian Welch, "Retirement Compensation Arrangements and the Prohibited Investment and Advantage Rules", Taxation of Executive Compensation and Retirement, Special Pension Edition, Volume XVI, No. 4, 2012, p. 1041: The article initially provides the following overview of the statutory scheme:

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Paragraph (a)

Administrative Policy

2017 Ruling 2016-0655071R3 - Supplemental employee retirement plan

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.5 - Subsection 207.5(1) - Subject Property of a Retirement Compensation Arrangement no subject property created when sub with SERP obligations is wound-up 166

2018 Ruling 2017-0720901R3 - Use of a Surety Bond by RCA

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(r) contributions (including re Pt XI.3 tax) for funding surety bond fees, currently deductible 209

Paragraph (c)

Administrative Policy

18 May 2017 Roundtable, 2017-0692331C6 - CLHIA 2017 Q3 - RCAs

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Specified Beneficiary

Articles

Manjit Singh, Jillian Welch, "Retirement Compensation Arrangements and the Prohibited Investment and Advantage Rules", Taxation of Executive Compensation and Retirement, Special Pension Edition, Volume XVI, No. 4, 2012, p. 1041, at 1042

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Subject Property of a Retirement Compensation Arrangement

Administrative Policy

2017 Ruling 2016-0655071R3 - Supplemental employee retirement plan

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.5 - Subsection 207.5(1) - Refundable Tax - Paragraph (a) the distribution to a non-resident parent of assets of a subsidiary that had SERP obligations and the assumption of such obligations did not create an RCA 466

Subsection 207.5(2) - Election

Administrative Policy

7 July 2014 External T.I. 2013-0511061E5 - Change in custodian of an RCA

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31 March 1995 External T.I. 5-950295 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(n.3) cancellation of LC 75

31 January 1994 T.I. 933685 HAA7200-9 (C.T.O. "Closing Out RCA Refundable Tax Account")

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Subsection 207.5(3)

Administrative Policy

15 May 2017 External T.I. 2015-0580461E5 F - Life insurance policy held in an RCA trust

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 207.5 - Subsection 207.5(1) - RCA Strip holding of life insurance policy could entail RCA strip 220