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Where benefits are paid in a form which has a lower actuarial equivalent than the normal form under the plan, the restrictions set out in A & B above must be respected. ... " (Signature) ^ (Position or rank of officer) ^ (c) Where benefits are provided through the use of an unallocated funding instrument (meaning, where some or all of the contributions are accumulated in an unallocated fund to be used to meet benefit payments as they come due or to purchase annuities for participants at retirement or on earlier termination of service with a vested right), the full valuation report of the actuary must be furnished giving the following data: (i) a brief history of the fund, (ii) a description of the benefits provided by the plan as at the valuation date, (iii) a statement, for both liabilities and assets, of the bases upon which the valuation was made. ...

Where benefits are paid in a form which has a lower actuarial equivalent than the normal form under the plan, the restrictions set out in A & B above must be respected. ... " (Signature) ^ (Position or rank of officer) ^ (c) Where benefits are provided through the use of an unallocated funding instrument (meaning, where some or all of the contributions are accumulated in an unallocated fund to be used to meet benefit payments as they come due or to purchase annuities for participants at retirement or on earlier termination of service with a vested right), the full valuation report of the actuary must be furnished giving the following data: (i) a brief history of the fund, (ii) a description of the benefits provided by the plan as at the valuation date, (iii) a statement, for both liabilities and assets, of the bases upon which the valuation was made. ...

A connected person is similar to a " significant shareholder" as defined in paragraph 8(d) of the Circular, with the exception that the "connected person" has a broader meaning than "significant shareholder". ...

Without a designated beneficiary or a spouse or common law partner at the time of the member's death, the balance of the account will be paid to the estate.   ...

The Department recognizes that in certain situations either a related group or an unrelated group of shareholders may control a corporation if they owned amongst themselves at least 50% + 1 of the issued and outstanding voting shares of the corporation at the same time and if they have historically acted in concert as a group. ...

. * Revised paragraphs are indicated by a side bar in the right margin. ...

If you have any comments about this circular, please write to: Revenue Canada Director General International Tax Programs Directorate Ottawa ON K1A 0L8 Appendix A Countries that have tax treaties with Canada: (January 1, 1995) Australia Austria Bangladesh Barbados Belgium Brazil Cameroon Cyprus Czech & Slovakia Federal Republic Denmark Dominican Republic Egypt Finland France Federal Republic of Germany Guyana India Indonesia Ireland Israel Italy Ivory Coast Jamaica Japan Kenya Republic of Korea Luxembourg Malaysia Malta Mexico Morocco The Netherlands New Zealand Norway Pakistan Papua New Guinea People's Republicof China Philippines Poland Romania Singapore Spain Sri Lanka Sweden Switzerland Thailand Date modified: 2002-08-26 ...

Universities & public colleges Note: These provisions do not include meal plans at a university or public college. ...

Agreed: For Canada Original signed by Mickey Sarazin Canadian Competent Authority Director General Legislative Policy Directorate Date: November 9, 2010 For the United States of America Original signed by Michael Danilack United States Competent Authority Deputy Commissioner (International) Large Business & International Division Date: November 12, 2010 [Footnote 1] In this memorandum of understanding, the term Board Member includes the Chair, unless the context requires otherwise. ...

In each year, the following amounts must be allocated either contingently or absolutely among the EPSP members: the contributions received by the trust from the employer or a corporation with whom the employer does not deal at arm's length; the profits from the property of the trust (computed without reference to capital gains or capital losses); after 1971, the capital gains and losses of the trust; after 1971 and before 1993, a specified percentage of the total amount which is a payment of tax deemed to have been made by the employee under subsection 144(9) (Before 1993, subsection 144(9) provided that the employee was deemed to have made a payment of tax equal to 15 % of the forfeited amount with respect to an employee who ceased to be a beneficiary under the EPSP for the year.); and after 1991, the total amount an employee is entitled to deduct under subsection 144(9). ...