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.

Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(r)
Services requirement (pp. 486-7)

Consistent with contributions to other pension arrangements, employer contributions to an RCA are deductible in...

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Summary Under
Tax Topics - Income Tax Act - Section 207.5 - Subsection 207.5(1) - Refundable Tax
Refund mechanics (p. 485)

When the employer makes a contribution to an RCA, one-half of the contribution must be remitted to the CRA [fn 22:...

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Summary Under
Tax Topics - Income Tax Act - Section 207.6 - Subsection 207.6(5)
Resident contribution rule (p. 491)

Under these rules, if a newcomer to Canada remains a member of his or her home-country pension plan for more...

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Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retirement Compensation Arrangement
Meaning of "substantial changes in the services" (p. 481)

CRA... will consider that there has been a substantial change in services for the...

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Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement
"One of the main purposes…is to postpone tax" (p. 483)

One might argue that a retirement arrangement was not established to defer tax where the...

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Summary Under
Tax Topics - Income Tax Act - Section 6 - Subsection 6(11)
Consequences of SDA (p. 484)

If a plan is characterized as an SDA, adverse tax consequences result. The amounts contributed to the plan would be...

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Summary Under
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(t)
Practical effect of limitation (p. 487)

In cases where an employee's contribution does not meet these conditions [for deduction under s....

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Summary Under
Tax Topics - Income Tax Act - Section 60.03 - Subsection 60.03(1) - Eligible Pension Income

Overview (p. 488)

…Spouses will now be able to split RCA distributions to the extent that the beneficiary of the income is at least 65 years of...

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Summary Under
Tax Topics - Income Tax Regulations - Regulation 6804 - Subsection 6804(6)
Resident contribution rule (p. 491)

Under these rules, if a newcomer to Canada remains a member of his or her home-country pension plan for more...

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Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 18
Retirement compensation arrangement as pension (p. 493)

[U]nder the model convention, payments from an RCA are likely to be considered a pension...

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