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Scraped CRA Website

Pooled Registered Pension Plans (PRPP)

According to subsection 147.5(2) of the ITA, the Minister of National Revenue will not accept a pooled pension plan for registration unless, in his or her opinion, the plan complies with the following conditions: The main purpose of the plan is to accept and invest contributions in order to provide retirement income to plan members, subject to the limits and other requirements of the ITA; One account is kept for each member under the member’s SIN: to which are credited all contributions made to the plan for the member, and any earnings of the plan allocated to the member; and to which are charged all payments and distributions made for the member; The only benefits provided under the plan for each member are benefits determined only with reference to, and provided by, the amount in the member’s account; All earnings of the plan are allocated to plan members on a reasonable basis and no less than once a year; An arrangement under which property is held in connection with the plan is acceptable to the Minister of National Revenue. ... A PRPP becomes a revocable plan at any time that: a contribution is made to the plan other than an amount: paid by a member of the plan; paid by the employer or former employer of a member of the plan in respect of the member; or transferred to the plan in accordance with any of subsections 147.5(21), 146(16) and (21), 146.3(14) and (14.1), 147(19) and 147.3(1), and (4) to (7) of the ITA; a contribution is made to the plan in respect of a member after the calendar year in which the member attains 71 years of age, other than a permissible transfer described above; a participating employer makes contributions to the plan in a calendar year in respect of a member of the plan in excess of the RRSP dollar limit for the year, except in accordance with a direction by the member; a distribution is made from the plan other than: a payment of benefits in accordance with subsection 147.5(5) of the ITA, or a return of contributions: if a contribution has been made as the result of a reasonable error by the member or participating employer and the return of contributions is made to the contributor no later than December 31 of the year following the calendar year in which the contribution was made; to avoid revocation of the registration of the plan; to reduce the amount of tax that would otherwise be payable, under Part X.1 by a member; or to comply with any requirement under the ITA; property is held in connection with the plan that: the administrator knew or ought to have known was a restricted investment for the plan; or in the case of a designated pooled pension plan, is a share or a debt of, or an interest in, a participating employer of the plan or any person or partnership that does not deal at arm’s length with a participating employer, or an interest (or for civil law, a right) in, or a right to acquire, such a share, debt or interest; (see ¶ 21.) the value of a member’s rights under the plan depends on the value of, or income or capital gains in respect of, property that would be described in paragraph 147.5(3)(e) of the ITA if it were held in connection with the plan; the administrator borrows money or other property for the purposes of the plan; or the plan or administrator does not comply with a prescribed condition. ... A designated pooled pension plan, for a calendar year, is defined in subsection 147.5(1) of the ITA as a pooled pension plan if, at any time in the year (other than the year in which the plan became registered as a PRPP), it meets any of the following conditions: the plan has fewer than 10 participating employers; the fair market value of property held in connection with the accounts of all members of the plan employed by a particular employer is more than 50% of the fair market value of the property held in connection with the plan; more than 50% of the members are employed by a particular participating employer; or it is reasonable to conclude that the participation in the plan of one or more participating employers occurs mainly to avoid the application of a, b, or c. ...
Current CRA website

Pooled Registered Pension Plans (PRPP)

According to subsection 147.5(2) of the ITA, the Minister of National Revenue will not accept a pooled pension plan for registration unless, in his or her opinion, the plan complies with the following conditions: The main purpose of the plan is to accept and invest contributions in order to provide retirement income to plan members, subject to the limits and other requirements of the ITA; One account is kept for each member under the member’s SIN: to which are credited all contributions made to the plan for the member, and any earnings of the plan allocated to the member; and to which are charged all payments and distributions made for the member; The only benefits provided under the plan for each member are benefits determined only with reference to, and provided by, the amount in the member’s account; All earnings of the plan are allocated to plan members on a reasonable basis and no less than once a year; An arrangement under which property is held in connection with the plan is acceptable to the Minister of National Revenue. ... A PRPP becomes a revocable plan at any time that: a contribution is made to the plan other than an amount: paid by a member of the plan; paid by the employer or former employer of a member of the plan in respect of the member; or transferred to the plan in accordance with any of subsections 147.5(21), 146(16) and (21), 146.3(14) and (14.1), 147(19) and 147.3(1), (4) and (5) to (7) of the ITA; a contribution is made to the plan in respect of a member after the calendar year in which the member attains 71 years of age, other than a permissible transfer described above; a participating employer makes contributions to the plan in a calendar year in respect of a member of the plan in excess of the RRSP dollar limit for the year, except in accordance with a direction by the member; a distribution is made from the plan other than: a payment of benefits in accordance with subsection 147.5(5) of the ITA, or a return of contributions: if a contribution has been made as the result of a reasonable error by the member or participating employer and the return of contributions is made to the contributor no later than December 31 of the year following the calendar year in which the contribution was made; to avoid revocation of the registration of the plan; to reduce the amount of tax that would otherwise be payable, under Part X.1 by a member; or to comply with any requirement under the ITA; property is held in connection with the plan that: the administrator knew or ought to have known was a restricted investment for the plan; or in the case of a designated pooled pension plan, is a share or a debt of, or an interest in, a participating employer of the plan or any person or partnership that does not deal at arm’s length with a participating employer, or an interest (or for civil law, a right) in, or a right to acquire, such a share, debt or interest; (see ¶ 21.) the value of a member’s rights under the plan depends on the value of, or income or capital gains in respect of, property that would be described in paragraph 147.5(3)(e) of the ITA if it were held in connection with the plan; the administrator borrows money or other property for the purposes of the plan; or the plan or administrator does not comply with a prescribed condition. ... A designated pooled pension plan, for a calendar year, is defined in subsection 147.5(1) of the ITA as a pooled pension plan if, at any time in the year (other than the year in which the plan became registered as a PRPP), it meets any of the following conditions: the plan has fewer than 10 participating employers; the fair market value of property held in connection with the accounts of all members of the plan employed by a particular employer is more than 50% of the fair market value of the property held in connection with the plan; more than 50% of the members are employed by a particular participating employer; or it is reasonable to conclude that the participation in the plan of one or more participating employers occurs mainly to avoid the application of a, b, or c. ...
Current CRA website

Pooled Registered Pension Plans (PRPP)

According to subsection 147.5(2) of the ITA, the Minister of National Revenue will not accept a pooled pension plan for registration unless, in his or her opinion, the plan complies with the following conditions: The main purpose of the plan is to accept and invest contributions in order to provide retirement income to plan members, subject to the limits and other requirements of the ITA; One account is kept for each member under the member’s SIN: to which are credited all contributions made to the plan for the member, and any earnings of the plan allocated to the member; and to which are charged all payments and distributions made for the member; The only benefits provided under the plan for each member are benefits determined only with reference to, and provided by, the amount in the member’s account; All earnings of the plan are allocated to plan members on a reasonable basis and no less than once a year; An arrangement under which property is held in connection with the plan is acceptable to the Minister of National Revenue. ... A PRPP becomes a revocable plan at any time that: a contribution is made to the plan other than an amount: paid by a member of the plan; paid by the employer or former employer of a member of the plan in respect of the member; or transferred to the plan in accordance with any of subsections 147.5(21), 146(16) and (21), 146.3(14) and (14.1), 147(19) and 147.3(1), (4) and (5) to (7) of the ITA; a contribution is made to the plan in respect of a member after the calendar year in which the member attains 71 years of age, other than a permissible transfer described above; a participating employer makes contributions to the plan in a calendar year in respect of a member of the plan in excess of the RRSP dollar limit for the year, except in accordance with a direction by the member; a distribution is made from the plan other than: a payment of benefits in accordance with subsection 147.5(5) of the ITA, or a return of contributions: if a contribution has been made as the result of a reasonable error by the member or participating employer and the return of contributions is made to the contributor no later than December 31 of the year following the calendar year in which the contribution was made; to avoid revocation of the registration of the plan; to reduce the amount of tax that would otherwise be payable, under Part X.1 by a member; or to comply with any requirement under the ITA; property is held in connection with the plan that: the administrator knew or ought to have known was a restricted investment for the plan; or in the case of a designated pooled pension plan, is a share or a debt of, or an interest in, a participating employer of the plan or any person or partnership that does not deal at arm’s length with a participating employer, or an interest (or for civil law, a right) in, or a right to acquire, such a share, debt or interest; (see ¶ 21.) the value of a member’s rights under the plan depends on the value of, or income or capital gains in respect of, property that would be described in paragraph 147.5(3)(e) of the ITA if it were held in connection with the plan; the administrator borrows money or other property for the purposes of the plan; or the plan or administrator does not comply with a prescribed condition. ... A designated pooled pension plan, for a calendar year, is defined in subsection 147.5(1) of the ITA as a pooled pension plan if, at any time in the year (other than the year in which the plan became registered as a PRPP), it meets any of the following conditions: the plan has fewer than 10 participating employers; the fair market value of property held in connection with the accounts of all members of the plan employed by a particular employer is more than 50% of the fair market value of the property held in connection with the plan; more than 50% of the members are employed by a particular participating employer; or it is reasonable to conclude that the participation in the plan of one or more participating employers occurs mainly to avoid the application of a, b, or c. ...
Current CRA website

Chapter History S1-F2-C3, Scholarships, Research Grants and Other Education Assistance

. ¶3.82 has been revised to delete previous wording that may have suggested that the deduction under paragraph 110(1)(g) is limited to tuition assistance that is received in connection with adult basic education. ¶3.82.1 has been added to provide examples of the types of training assistance to which the deduction under paragraph 110(1)(g) may apply. ... However, these sections now appear in the Table of contents for easy access; the statement that folios are only available in electronic format has been moved to the end of the Application section; and the words “as promulgated under the Act” in connection with the Income Tax Regulations have been removed from the Application section, in the interest of using plain language. ... This amendment was made by 2007, c. 2, s. 6(3), effective for the 2006 and subsequent tax years, to increase the $3,000 exemption to an unlimited exemption where scholarship income was received in connection with an educational program that qualified under subsection 118.6(2). ¶3.91 (formerly included in ¶43 of IT-75R4) has been revised to reflect the amendment to paragraph 56(3)(a) to effectively extend (i) to the preceding and following years. ...
Archived CRA website

ARCHIVED - Transactions Involving Eligible Capital Property

This bulletin also discusses other topics in connection with eligible capital property, including the transition from the old system to the new system. ... Where subsection 14(3) applies, the transferee's EC expenditure is "deemed" (determined) to be 4/3 of (a) the amount determined by the transferor as the EC amount from the disposition of the property minus (b) the total of all amounts that may reasonably be considered to have been claimed as a section 110.6 capital gains deduction by the transferor or any other person with whom the transferee was not dealing at arm's length in connection with the transferor's disposition of the property to the transferee or in connection with any previous disposition of the same property. ... In this connection, see the transitional rules described in ¶s 28 and 29 above. ...
Archived CRA website

ARCHIVED - Transactions Involving Eligible Capital Property

This bulletin also discusses other topics in connection with eligible capital property, including the transition from the old system to the new system. ... Where subsection 14(3) applies, the transferee's EC expenditure is "deemed" (determined) to be 4/3 of (a) the amount determined by the transferor as the EC amount from the disposition of the property minus (b) the total of all amounts that may reasonably be considered to have been claimed as a section 110.6 capital gains deduction by the transferor or any other person with whom the transferee was not dealing at arm's length in connection with the transferor's disposition of the property to the transferee or in connection with any previous disposition of the same property. ... In this connection, see the transitional rules described in ¶s 28 and 29 above. ...
Archived CRA website

ARCHIVED - Transactions Involving Eligible Capital Property

This bulletin also discusses other topics in connection with eligible capital property, including the transition from the old system to the new system. ... Where subsection 14(3) applies, the transferee's EC expenditure is "deemed" (determined) to be 4/3 of (a) the amount determined by the transferor as the EC amount from the disposition of the property minus (b) the total of all amounts that may reasonably be considered to have been claimed as a section 110.6 capital gains deduction by the transferor or any other person with whom the transferee was not dealing at arm's length in connection with the transferor's disposition of the property to the transferee or in connection with any previous disposition of the same property. ... In this connection, see the transitional rules described in ¶s 28 and 29 above. ...
Ruling

2009 Ruling 2008-0304371R3 - Single-Wing Butterfly

To the best of your knowledge, and that of the taxpayers involved, none of the issues involved in this ruling request is (i) in an earlier return of any of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of any of the taxpayers or a related person; (iii) under objection by any of the taxpayers or a related person; (iv) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or (vi) the subject of a ruling previously issued to a taxpayer involved or a related person. ...
Ruling

2008 Ruling 2007-0251681R3 - Butterfly and freeze of an estate

To the best of your knowledge and that of the above-referenced taxpayer, none of the issues involved in this ruling is: (a) in an earlier return of the above-referenced taxpayer or a related person; (b) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the above-referenced taxpayer or a related person; (c) under objection by the above-referenced taxpayer or a related person; (d) before the courts; or (e) the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...
Ruling

2000 Ruling 2000-0003253 - Safe income

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (i) is in an earlier return of the taxpayer or a related person; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) is under objection by the taxpayer or a related person; (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of a ruling previously issued by the Income Tax Rulings Directorate. ...

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