Principal Issues: Whether amounts received by a resident of Canada from a UK retirement plan where the employer makes contributions to the plan which are attributable to services rendered by the individual while resident in the UK, would be included in the income of the individual for Canadian tax purposes?
Position: Generally, yes.
Reasons: Where the plan is determined to be a pension, the amounts would be included in income pursuant to subparagraph 56(1)(a)(i), subject to certain criteria. If the plan is not a pension, the amounts would be included in income pursuant to paragraph 6(1)(g).
