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The Act generally defines a "superannuation or pension plan" to be a plan 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 contributions are used to provide an annuity or other periodical payment on or after the employee's retirement in consideration for his or her employment services. ...

5 October 2012 Roundtable, 2012-0453161C6 F- RRIF, prohibited investment, minimum amount CRA Tags 207.05(4) 146.3(1) Principal Issues: Whether the "transitional prohibited investment benefit" amount that is withdrawn from a registered retirement income fund (RRIF) can be taken into consideration for the carrier obligation to pay the minimum amount? ... L’ARC est d’avis qu’un montant retiré d’un FERR afin de bénéficier de la règle transitoire énoncée au paragraphe 207.05(4) L.I.R. est un montant que l’émetteur a versé au rentier et qui peut être pris en considération pour satisfaire l’exigence du minimum à être versé du FRR au sens du paragraphe 146.3(1). ...

The determination in a particular situation would be based on consideration of all the relevant facts and supporting documents. This may include consideration of an opinion of a qualified medical practitioner describing the nature and purpose of the procedure in enough detail to be able to make a determination. ...

However, in our view for paragraph 95(2)(i) to apply notwithstanding such delay, the taxpayer should be prepared to establish that the brief delay could not practically have been avoided and was not attributable to financial considerations like a desire to earn a return from a non-qualifying investment, to avoid temporary cash flow issues or because of exchange rate considerations. b. ...

In your hypothetical situation, a farm client is in the process of dividing his remaining farmland amongst his children and that the consideration was to be partially in the form of cash and the balance in a promissory note or mortgage. ... Another consideration would be the potential application of the attribution rules in Section 75.1 of the Act if the children are minors. ...

The scenario you have described results in an employee disposing of the employee’s rights under a stock option for consideration equal to the stock option’s intrinsic or in-the-money value where the consideration is paid in employer treasury shares. ...

4 August 2016 Internal T.I. 2016-0645521I7- 90(6) & sale of creditor affiliate Unedited CRA Tags 90(6); 90(8)(a); 90(14) Principal Issues: Whether the exception in 90(8)(a) would apply where the "creditor affiliate" is sold for cash consideration before the 2-year time limit? ... Facts For illustrative purposes, we will use the following assumed facts: • A non-resident corporation (Foreign Parent) owns all the issued and outstanding shares of a corporation resident in Canada (Canco) and another non-resident corporation (SisterCo). • Canco owns all the issued and outstanding shares of another non-resident corporation (FA). • In 2013, FA makes a loan to SisterCo. • Before the expiration of the two year time limit specified in paragraph 90(8)(a), Canco sells its shares of FA to Foreign Parent for cash consideration. • The loan remains outstanding for more than two years. ...

Parent will receive new shares of Canadian Parent as consideration for its shares of Holdco and Canadian Parent will receive all of the shares of Amalco as consideration for its shares of CanSub. ...

The CRA generally defines a superannuation or pension plan to be a plan 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 contributions are used to provide an annuity or other periodic payment on or after the employee's retirement in consideration for his or her employment services, and, in some cases, where amounts have been contributed under the plan by a government. ...

Reasons: Consultations took into account the administrative feasibility and tax policy considerations. ... A consultation process was undertaken in which consideration was given to the formulaic approach for the computation of stub period income for participants of joint ventures. ...