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Generally, a plan will be considered to be a pension plan under the Act where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payment on or after the employee’s retirement. ...

The following transactions will be undertaken in year 2: Canco 2 will agree to repay the Loan on behalf of Canco 1 at maturity and as consideration for that undertaking, Canco 1 will issue a Canadian dollar denominated note (the “Canco 1 Note”) payable to Canco 2. ...

In general terms, subsection 18(9.1) may apply to a penalty payment or bonus, paid in the course of carrying on a business or earning income from property, in consideration of the early repayment of all or part of a borrowing or an unpaid purchase price for property. ...

In some of these circumstances, consideration can be given to whether it may be better for taxpayers to determine whether the amount is excluded from the TOSI because it is a reasonable return of the individual based on the factors applicable in the circumstances. ...

A. is that they would not be reasonable expenses of XXXXXXXXXX within the meaning of section 67 of the Act, for we are not able to answer the question: “Would a reasonable business person have contracted to pay such amounts having only business considerations in mind?” ...

Department’s Position The determination of how the foreign affiliate provisions apply to the money lending activities of a financing affiliate is a complex subject, requiring an in-depth understanding of the arrangements under consideration. ...

As stated in paragraph 3 of the attached Interpretation Bulletin IT-339R2, Meaning of “Private Health Services Plan”, a plan (other than one that is provided by means of a contract of insurance with an insurer) must containing the following basic elements of insurance in order to qualify as a PHSP: (a) an undertaking of one person, (b) to indemnify another person, (c) for an agreed consideration, (d) from a loss or liability in respect of an event, (e) the happening of which is uncertain. ...

I note that his letter has previously been forwarded to the Department of Finance for their consideration. ...

Furthermore, the same analysis has to take into consideration the possible application of any of provisions in paragraphs 251(2)(b) and (c) of the Act. ...

This is something that may warrant further review so you might consider referring the matter to the local T.S.O. for consideration on audit. ...