new RCA trust permits the retired employee to request an immediate payout on “a material deterioration in the Canadian economy”
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Principal Issues: (1) Will the proposed supplemental plan qualify as an RCA? (2) If so, will the proposed transfer of property from the existing RCA to the new RCA qualify as a transfer under subsection 207.6(7)?
Principal Issues: Whether the payments made by a government program, directly to caregivers to provide support services to adults with developmental disabilities, will be exempt from income tax.
Position: Yes, if the amounts that the caregiver receives are for the benefit of the care recipients, and provided that all the other required conditions in paragraph 81(1)(h) are met, then these amounts will likely qualify for the exemption under paragraph 81(1)(h) of the Act.
Reasons: All the conditions of paragraph 81(1)(h) of the Act must be met.
