Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.
Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ADRC.
Principal Issues:
1- Corporation and Trust are dealing at arm's length?
2- Shareholder's benefit for contributions by the Corporation to the Trust?
3- Could it be said that a plan will not qualify as an insurance plan if the premiums could revert to the Corporation?
4- What provisions that can be relied upon in denying the deductions of the contributions?
5- Can a penalty be levied?
6- Is it gaarable?
7- Attribution rules applicable?
Position:
1- No.
2- Maybe (we do not have a complete picture).
3- No.
4- It will depend on the plan under review.
5- Dealt verbally.
6- Not considered.
7- Yes.
Reasons:
1- Subsection 251(1) of the Income Tax Act (the "Act").
2- Subsection 15(1) of the Act.
3- Definition of "insurance" of the Insurance Act of Ontario.
4- Paragraph 18(1)(b) and subparagraph 18(9)(a)(iii) of the Act.
5- Dealt verbally.
6- In light of the above.
7- Subsection 75(2) of the Act.
January 2, 2003
Mr. André Turgeon Pascal Tétrault
Offshore Trust Project 957-4353
Laval Tax Services Office
3131 St-Martin Boulevard West, Suite 520
Laval (Québec) H7Z 2A7
2002-015262
Subject: Non-Resident Trust
We are writing in response to your memorandum dated July 12, 2002, requesting our views on several questions regarding the interpretation of the Income Tax Act (the "Act").
The facts in issue involve the creation by a Canadian corporation residing in Ontario, XXXXXXXXXX (the "Corporation"), of a trust resident in XXXXXXXXXX (the "Trust") having as beneficiaries the only two shareholders of the Corporation, XXXXXXXXXX, and their dependants. The trustee is a bank resident in XXXXXXXXXX and is also a subsidiary of a Canadian bank.
The Trust was established by the Memorandum of Agreement (the "Memorandum") and is said to provide XXXXXXXXXX and their children with dental insurance, disability benefits and medical expense benefits. The Corporation made contributions to the Trust in the amount of $XXXXXXXXXX. In the XXXXXXXXXX years, the Corporation had another employee who was not a shareholder of the Corporation and he was not a beneficiary of the Trust.
The beneficiaries are entitled to the reimbursement of all dental expenses and all health care services or supplies. The beneficiaries are also entitled to a salary loss replacement of up to $XXXXXXXXXX a year if they are prevented from performing their employment and as a result of sickness or accidental bodily injury.
Two other documents inextricably related to the Memorandum are the XXXXXXXXXX Health and Welfare Insurance Plan (the "Plan") executed on XXXXXXXXXX , and the Initial Actuarial Valuation as at XXXXXXXXXX, which further defines the funding requirements of the Trust.
The Memorandum provides that the trust fund shall be dealt with in accordance with the provisions of the Memorandum and the Plan.1 The Memorandum is to the effect that the contributions shall not be returned to the employer.2 However, the Plan provides that it can be amended or terminated at any time by the Corporation and that the contributions shall be returned to the Corporation.
YOUR POSITION
You have reassessed the Corporation for the XXXXXXXXXX years on the basis that the contributions can revert back to the Corporation and that as such the contributions cannot be viewed as a Health and Welfare Trust.
TAXPAYER'S POSITION
The taxpayer submits in a letter dated May 10, 2002, that there is no legal basis for you to conclude that the possible reversion of the trust fund disqualifies the Trust from being a Health and Welfare Trust. The taxpayer further submits that the XXXXXXXXXX years are statute barred and that the Corporation and the trustee are dealing at arm's length which is preventing you from reassessing those years.
OUR POSITION
This letter is based on the written documents provided to us and the analysis provided herein may vary according to facts not provided to the author. You have asked us several questions which will be dealt with in the order they were submitted.
What can be inferred from the establishment of the Trust is that the Corporation wanted to avoid tax on the passive income earned in the trust while being eligible to have the contributions deducted from its income as contributions to a Health and Welfare Trust. This purpose can be inferred from the fact that the only connecting factor to the tax haven jurisdiction of XXXXXXXXXX is the trustee and that all of the other interested parties involved are Canadians.
QUESTION 1: THE CORPORATION AND THE TRUST ARE AT ARM'S LENTH?
Your first question is whether the Corporation and the Trust were dealing at arm's length. Such a determination will allow the Minister of National Revenue to reassess the corporation beyond the normal reassessment period according to subparagraph 152(4)(b)(iii) of the Act. Subparagraph 152(4)(b)(iii) of the Act states:
(4) Assessment and reassessment [limitation period] - The Minister may at any time make an assessment, reassessment or additional assessment of tax for a taxation year, interest or penalties, if any, payable under this Part by a taxpayer or notify in writing any person by whom a return of income for a taxation year has been filed that no tax is payable for the year, except that an assessment, reassessment or additional assessment may be made after the taxpayer's normal reassessment period in respect of the year only if
[...]
(b) the assessment, reassessment or additional assessment is made before the day that is 3 years after the end of the normal reassessment period for the taxpayer in respect of the year and
[...]
(iii) is made as a consequence of a transaction involving the taxpayer and a non-resident person with whom the taxpayer was not dealing at arm's length,
[emphasis added]
We must determine if the Corporation was not dealing at arm's length with the Trust. Section 251 defines circumstances in which persons are considered not to deal with each other at arm's length for the purposes of the Act. Subsection 251(1) of the Act states:
251. (1) Arm's length - For the purposes of this Act,
(a) related persons shall be deemed not to deal with each other at arm's length;
(b) a taxpayer and a personal trust (other than a trust described in any of paragraphs (a) to (e.1) of the definition "trust" in subsection 108(1)) are deemed not to deal with each other at arm's length if the taxpayer, or any person not dealing at arm's length with the taxpayer, would be beneficially interested in the trust if subsection 248(25) were read without reference to subclauses 248(25)(b)(iii)(A)(II) to (IV); and
(c) where paragraph (b) does not apply, it is a question of fact whether persons not related to each other are at a particular time dealing with each other at arm's length.
Subsection 251(1) was amended by 2001. c. 17, s. 192 by adding the above paragraph (b). Before the amendment, the current paragraph (c) was found under paragraph (b) and it read as follows:
(b) it is a question of fact whether persons not related to each other were at a particular time dealing with each other at arm's length.
The amendment is said to "apply after December 23, 1998". Accordingly, it is only if the transaction giving rise to the reassessment was made after December 23, 1998, that the new paragraph 251(1)(b) of the Act can be relied upon in applying subparagraph 152(4)(b)(iii) of the Act.
i) After the amendment: the new deeming rule
Paragraph 251(1)(b) of the Act deems that a taxpayer and specified personal trust are not dealing at arm's length in certain circumstances.
Two elements need to be addressed in order to determine if our situation comes within the ambit of paragraph 251(1)(b) of the Act. First, paragraph 251(1)(b) of the Act will be applicable in the present factual scenario if the property is held by the trust for the purposes of providing benefits to individuals in their capacity as shareholders rather than in their capacity as employees. This point is essential because of the exclusion in paragraph 251(1)(b) of trusts where the property is held for the purposes of providing benefits to individuals in respect of, or because of, an office or employment. Second, paragraph 251(1)(b) of the Act will be applicable if persons not dealing at arm's length with the Corporation are beneficially interested in the Trust as per subsection 248(25) of the Act.
Regarding the first condition, we are not confident taking the position that the benefits were conferred to XXXXXXXXXX in their capacity of shareholders. Further comments are provided in the answer to your second question.
Regarding the second condition, XXXXXXXXXX are not dealing at arm's length with the Corporation and are beneficially interested in the Trust according to subsection 248(25) of the Act. The result is that the Corporation and the Trust would be deemed not to deal with each other at arm's length according to paragraph 251(1)(b) of the Act if the first condition was met.
In the event that the benefits are conferred qua shareholders, XXXXXXXXXX would be deemed not to deal at arm's length with the Corporation by the combined effect of paragraph 251(1)(a), subparagraph 251(2)(b)(i) and the definition of "related group" found in subsection 251(4) of the Act. The fact that XXXXXXXXXX are not dealing at arm's length with the Corporation and are beneficially interested (subsection 248(25)) in the Trust would result in the Corporation and the Trust being deemed not to deal at arm's length as per paragraph 251(1)(b) of the Act if the first condition was met.
It must be noted with respect to the above analysis that in the present case, the years in issue are the XXXXXXXXXX years and the transactions giving rise to the reassessment were concluded before the entry into force of the new paragraph 251(1)(b) of the Act. Accordingly, the new paragraph 251(1)(b) cannot be relied upon. We must thus consider whether the facts in issue indicate that the Trust and the Corporation are not dealing at arm's length.
ii) Before the amendment: relying on the de facto arm's length test
The concept of arm's length has been the subject of a number of decisions by the Canadian courts. In an oft-quoted passage on the issue Cattanach J. said, in the Minister of National Revenue v. Merritt, [1969] C.T.C. 207 (Ex.Ct.):
In my view, the basic premise on which this analysis is based is that, where the "mind" by which the bargaining is directed on behalf of one party to a contract is the same "mind" that directs the bargaining on behalf of the other party, it cannot be said that the parties are dealing at arm's length. In other words where the evidence reveals that the same person was "dictating" the "terms of the bargain" on behalf of both parties, it cannot be said that the parties were dealing at arm's length.3
The Supreme Court of Canada in Swiss Bank Corp. v. Minister of National Revenue found that certificate holders and a Canadian company were not dealing at arm's length because they were acting without separate interest. The Swiss Bank Corporation and the Swiss Credit Bank acted as trustee for the funds provided by the certificate holders. The Swiss Bank Corporation and the Swiss Credit Bank together with a third bank were shareholders of a Swiss corporation which held all of the shares of the Canadian company. The Swiss corporation also acted as manager of the funds of the certificate holders. Laskin J. described the relationship between the parties as follows:
In my opinion, the interposition of the managing agent and the two depositaries between City Park [the Canadian company] and the certificate holders does not, despite the regulations, create an arm's length situation between them, within the exception in clause 106(1)(b)(iii)(A). City Park owes its very existence to the funds provided by the certificate holders, is without support from any other source and those funds are committed to provide a return only to the certificate holders. In short, City Park is completely a captive to the interests of the certificate holders, acting through professional managers and fiduciaries.4
[emphasis added]
Bonner T.C.J. in Noranda Mines Ltd v. Minister of National Revenue, [1987] 2 C.T.C. 2089 (T.C.C.) on the arm's length principle also said:
The arm's length test looks to the presence or absence of the power to influence or control. An unusual result may well be indicative of the absence of an arm's length relationship, but the fact that a result is typical of what might be expected between parties who do deal at arm's length does not negative the existence of a non-arm's length relationship.5
The Tax Court of Canada in May Estate v. Minister of National Revenue, [1988] 1 C.T.C. 2303 relied, inter alia, on the above authorities to conclude that a trust and the settlor of the trust were not dealing at arm's length.
In the situation under review a number of elements indicate that the Corporation is not dealing at arm's length with the Trust. The Plan, which forms an integral part of the Memorandum because of the requirement that the trust fund be dealt according to the Plan and of the Memorandum,6 can be terminated or amended at any time and for any reason by the Corporation. The Memorandum, for its part, provides that the Corporation and the trustee may amend the Memorandum by mutual agreement. However, the Memorandum also provides that the Corporation may replace the trustee simply by giving a notice.
The Federal Court of Appeal in Robson Leather Co. v. Minister of National Revenue, [1977] C.T.C. 132, looked at the concept of arm's length dealings in the context of a trust. More specifically, the court looked at the power which could result from the removal of a trustee by another trustee. The three trustees had to be unanimous in exercising their powers. The taxpayer argued that:
[...] it could not be assumed that the trustees would not carry out their duties as trustees in accordance with the legal obligations imposed on trustees to formulate their own judgments in matters affecting the trusts, but rather would follow Robson's instructions merely because he had the power to cause the retirement of either or both of the other two trustees if they did not do so.7
The Federal Court of Appeal rejected this argument and adopted the pronouncement of the Federal Court - Trial Division which is useful in the present case and which reads as follows:
In my opinion, however, in deciding the larger issue before me, I must look at the practical and business reality of the operation of the trust. By demanding retirement of trustees, or even the threat of such a demand, or the knowledge in the co-trustees that the ultimate power was always in Mr Robson, I have no doubt that Mr Robson, for practical and legal purposes, controlled the trust and, therefore, controlled Robson Leather. I add the caveat here, that share control alone (or absence of it) is not necessarily conclusive; it is a factor to be considered in determining questions of "arm's length".8
The present case is different from the underlying facts of the Robson Leather Case, however the essence of the above excerpt can be applied here. It is reasonable to conclude that from a practical and business reality, the Corporation, which is the settlor of the Trust, is dictating the terms of the bargain on behalf of the Corporation and the Trust and that the Corporation is acting without separate interest with the Trust. What greater degree of influence and control can an entity have over another when it can, at any time, dictate the rules under which the other entity is governed and even trigger its collapse. The fact that the Memorandum provides that an amendment requires the mutual agreement of the trustee and of the Corporation does little to limit the degree of influence of the Corporation over the Trust. In the event that the trustee would oppose an amendment, the Corporation could demand the replacement of a "difficult" trustee by another who would comply with the wishes of the Corporation. By analogy with the Robson Leather Case, the only threat of retirement or the knowledge by the trustee of the power to be removed by the Corporation is sufficient for the Corporation to have the necessary influence over the trustee.
It should be noted that in the context of determining whether a person is at arm's length with a trust, the relationship between the trustee and the person is of importance. However this is not the only element to consider. A trust being deemed for the purposes of the Act to be an individual,9 the relationship between the trust as an entity in itself and the other person must be considered.
You have indicated that the Memorandum was amended after the taxation years in issue. Circumstances surrounding the amendment of the Memorandum should be examined in order to find further evidence of the relationship between the Corporation and the Trust. For the above reasons, we conclude that the Corporation and the Trust are not dealing at arm's length.
QUESTION 2: IS THERE A SHAREHOLDER'S BENEFIT?
You ask whether the facts are sufficient to establish that the amounts paid by the Trust should be included in XXXXXXXXXX hands as shareholders' benefits pursuant to subsection 15(1) of the Act and to disallow the contributions by the Corporation to the Trust pursuant to paragraph 18(1)(a) of the Act.
The facts submitted do not clearly indicate that the contributions to the Trust are made to XXXXXXXXXX in their capacity as shareholders. We have noted that there was another employee of the Corporation who was not covered by the Plan at the time the contributions were made. You have not provided any information regarding the type of services the employee was performing. If the employee who was not covered by the Plan had a similar position as the others covered by the Plan, we would likely come to the conclusion that the Trust was set up as a device to confer benefits to the individuals in their capacity of shareholders.
QUESTION 3: THE AMOUNTS OF CONTRIBUTIONS WERE BASED ON AN ACTUARIAL REPORT COVERING THE POTENTIAL DISABILITY. HOWEVER, THE CONTRIBUTIONS COULD REVERT TO THE EMPLOYER. COULD WE SAY THAT THE PLAN WOULD NOT BE AN INSURANCE PLAN BECAUSE THE PREMIUMS COULD BE REIMBURSED TO THE EMPLOYER?
The Act does not define the terms "insurance plan" or "insurance". In looking at the laws of the province of residence of the Corporation which is Ontario, the Insurance Act, R.S.O. 1990, c. I.8. defines the word "insurance" as follows:
"insurance" means the undertaking by one person to indemnify another person against loss or liability for loss in respect of a certain risk or peril to which the object of the insurance may be exposed, or to pay a sum of money or other thing of value upon the happening of a certain event, and includes life insurance; ("assurance")
According to this definition of "insurance", we are of the opinion that the fact that the premiums could be reimbursed to the Corporation would not prevent the qualification of the Plan as insurance for the purposes of the Act and the Insurance Act.
The evidence reveals that claims were actually made to the Trust regarding the benefits covered and that payments were made to the people entitled to them. However, as noted in paragraph 6 of Interpretation Bulletin IT-85R2 - Health and Welfare Trusts for Employees, to qualify as a Health and Welfare Trust the funds of the trust cannot revert to the employer.
QUESTION 4 & 5: IF THE TRUST IS NOT A HEALTH AND WELFARE TRUST, WHAT PROVISIONS OF THE ACT CAN BE RELIED UPON TO DISALLOW THE CONTRIBUTIONS?
We would like to mention that Health and Welfare Trusts are not defined or described in the Act. They are recognized administratively by the Canada Customs and Revenue Agency (the CCRA) in the manner set out in Interpretation Bulletin IT-85R2.
In the event that a trust does not meet the criteria set out in Interpretation Bulletin IT-85, the CCRA will carefully scrutinize each structure in order to determine its conformity with the Act.10
In the present case, the payment by the Corporation to the Trust is a payment on account of capital for which no deduction can be taken from the Corporation's income from business as per paragraph 18(1)(b) of the Act.
The Supreme Court of Canada in Johns-Manville Canada v. The Queen11 summarized a number of tests used to distinguish a capital expenditure from a current expenditure. One of the tests adopted by the Supreme Court was the one formulated in the dictum of Viscount Cave L.C. in British Insulated And Helsby Cables, Ltd. v. Atherton12 which reads as follows:
[W]hen an expenditure is made not only once and for all, but with a view to bringing into existence an asset or an advantage for the enduring benefit of a trade, I think that is a very good reason (in the absence of special circumstances leading to an opposite conclusion) for treating such an expenditure as properly attributable not to revenue but to capital.13
These words are often referred to but it should be remembered that the decision of the House of Lords was based on a factual scenario similar to the present case. In the British Insulated Case, the company did not pay any pensions to its retiring employees and decided to set up a pension fund. A pension fund was therefore constituted by a trust deed for which it was stated that the employees would contribute a percentage of their salary to the plan and the employer would make contributions equivalent to one half of the contributions of the employees. The employer also undertook to pay a lump sum payment to the pension fund which was referred to as the "nucleus of the fund". The sole question was whether the lump sum payment to the fund was in the nature of a charge against revenue rather than a charge against capital.
In concluding that the payment was in the nature of a capital expenditure, Viscount Cave L.C. said:
The payment of £31,784 which is the subject of dispute, was made, not merely as a gift or bonus to the older servants of the appellant company, but (as the deed shows) "to form a nucleus" of the pension fund which it was desired to create; and it is a fair inference from the terms of the deed and from the commissioners' findings that without this contribution the funds might not have come into existence at all.
The object and effect of the payment of this large sum was to enable the company to establish the pension fund and to obtain from the company the substantial and lasting advantage of being in a position throughout its business life to secure and retain the services of efficient staff.14
We fail to distinguish on a material aspect the British Insulated Case with the facts under review. The Corporation made lump sum payments of $XXXXXXXXXX which constituted the "nucleus" of the Plan which is said to be for the benefit of the employees of the Corporation.15 The payments had the effect of bringing into existence an asset or an advantage for the enduring benefit of the business of the Corporation. The Corporation was in a position to secure and retain the services of efficient staff. Evidence that the Plan was to the benefit of the Corporation is that the employees are covered to the extent that they remain employed by the corporation which is an indication that the advantage created is connected to the Corporation. Evidence that the arrangement is created to provide an enduring benefit may be found in Article XI of the Plan where it is said that the Plan is "established with the bona fide intention and expectation that it will continue indefinitely".
XXXXXXXXXX
QUESTION 6: A PENALTY CAN BE LEVIED?
We already have addressed this concern with you verbally.
QUESTION 7: IS GAAR APPLICABLE?
In light of the answers given above, we have not considered the application of section 245 of the Act.
We would like to stress the application of subsection 75(2) of the Act in the present case which would operate to allocate the income from property and taxable capital gain generated from the contributions back to the Corporation. Subsection 75(2) of the Act states:
(2) Trusts - Where, by a trust created in any manner whatever since 1934, property is held on condition
(a) that it or property substituted therefor may
(i) revert to the person from whom the property or property for which it was substituted was directly or indirectly received (in this subsection referred to as "the person"), or
(ii) pass to persons to be determined by the person at a time subsequent to the creation of the trust, or
(b) that, during the existence of the person, the property shall not be disposed of except with the person's consent or in accordance with the person's direction, any income or loss from the property or from property substituted for the property, and any taxable capital gain or allowable capital loss from the disposition of the property or of property substituted for the property, shall, during the existence of the person while the person is resident in Canada, be deemed to be income or a loss, as the case may be, or a taxable capital gain or allowable capital loss, as the case may be, of the person.
In the present case, the Memorandum provides that the trust fund shall be dealt with in accordance with the provisions of the Memorandum and the Plan.16 The Memorandum is to the effect that the contributions shall not be returned to the employer. However, the Plan provides that it can be amended or terminated at any time by the Corporation and that the contributions shall be returned to the Corporation. Notwithstanding the prohibition under the Memorandum that the contributions to the Trust shall not return to the Corporation, the Memorandum refers to the Plan which becomes an integral part of the Memorandum. Accordingly, the property transferred to the Trust can be said to be held on the condition that it may revert to the Corporation for the purposes of subsection 75(2) of the Act.
Subsection 75(2) of the Act can also be said to operate in the present case because the contributions may pass to persons to be determined by the Corporation at a time subsequent to the creation of the Trust as per subparagraph 75(2)(a)(ii) of the Act. This is because the Corporation may at any time amend the Plan on its own will and the Memorandum may be amended with the approval of the Trustee.
In reviewing the information at hand, the present situation appears not to fall within the exceptions to the application of subsection 75(2) listed in subsection 75(3) of the Act as applicable for the years in issue.
In dealing with non-resident trusts, subsection 94(1) of the Act may be of application. However, when subsection 75(2) and 94(1) of the Act are both applicable, the former takes precedence.
For your information, a copy of this memorandum will be severed using the Access to Information Act criteria and placed in the CCRA's electronic library. A severed copy will also be distributed to the commercial tax publishers for inclusion in their databases. The severing process will remove all material that is not subject to disclosure, including information that could disclose the identity of the taxpayer. Should your client request a copy of this memorandum, they can be provided with the electronic library version, or they may request a severed copy using the Privacy Act criteria, which does not remove client identity. Requests for this latter version should be made by you to Mrs. Jackie Page at (819) 994-2898. A copy will be sent to you for delivery to the client.
If additional comments are needed with respect to the position taken in this letter, please contact the author at (613) 957-4363.
Yours truly,
Alain Godin
Section Manager
for Division Director
International and Trusts Division
Income Tax Rulings Directorate
Policy and Legislation Branch
ENDNOTES
1 Clause XXXXXXXXXX of the Memorandum. See also the second "XXXXXXXXXX" of the Memorandum.
2 Clause XXXXXXXXXX of the Memorandum.
3 [1969] C.T.C. 207, at 217 (Ex.Ct.).
4 Swiss Bank Corp. v. Minister of National Revenue, [1972] C.T.C. 614, at 618 (S.C.C.).
5 [1987] 2 C.T.C. 2089, at 2095 (T.C.C.).
6 See the second "XXXXXXXXXX" and clause XXXXXXXXXX of the Memorandum.
7 Robson Leather Co. v. Minister of National Revenue, [1977] C.T.C. 132, at 141 (F.C.A.).
8 ibid.
9 Subsection 104(2) of the Act.
10 The favourable treatment granted to Health and Welfare Trusts and in particular, the deductibility of payments made to the trust by the employer may thus be at risk.
11 [1985] 2 S.C.R. 45 (S.C.C.).
12 [1925] All E.R. 623 (U.K. H.L.).
13 id. at p. 629.
14 id. at p. 630.
15 To conclude that the benefit was not conferred for the benefit of the employees of the Corporation would result in the benefits being conferred qua shareholder with the application of subsection 15(1) of the Act to include the contributions in the shareholders hands and accordingly deny the deduction of the Corporation under subsection 18(1)(a) of the Act.
16 clause XXXXXXXXXX of the Memorandum. See also the second "XXXXXXXXXX" of the Memorandum.
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