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24 January 2005 External T.I. 2004-0099471E5 F - Convention de retraite pour un actionnaire-employé -- summary under Salary Deferral Arrangement

24 January 2005 External T.I. 2004-0099471E5 F- Convention de retraite pour un actionnaire-employé-- summary under Salary Deferral Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement a significant reduction in bonus or salary matched by an RCA contribution likely suggests it instead is an SDA After noting that contributions by a corporation to an RCA would not be deductible in computing its income where the contributions related to services rendered by a shareholder-employee while self-employed and before the corporation’s incorporation, or to the extent that s. 67 applied, CRA turned to the question whether there would be an SDA if the corporation regularly reduced bonuses to a shareholder-employee by the amount of related contributions to the employee RCA for its employees, and stated: Where a plan or arrangement can qualify as both an RCA and an SDA, it will be treated as an SDA …. … [I]t can be assumed that, except in special circumstances, where a portion of an employee's salary or wages is deferred under an agreement, one of the main purposes is to defer the payment of taxes. … [W]here a significant portion of the salary or bonus to which a shareholder-employee is entitled for services rendered is reduced so as to be contributed to an RCA instead, the existence of the RCA could be questioned since the contribution made by the employer may not relate to benefits that are receivable at retirement. ...

2 February 2005 External T.I. 2004-0104671E5 F - Convention de retraite - Fonds mis de côté -- summary under Retirement Compensation Arrangement

2 February 2005 External T.I. 2004-0104671E5 F- Convention de retraite- Fonds mis de côté-- summary under Retirement Compensation Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement no requirement that payment to the other be in trust In a general response to a query as to whether a special reserve fund that an employer creates by depositing money with a broker to provide for the payment of a portion of a pension payable for the retirement of a management employee will constitute a salary deferral arrangement or a retirement compensation arrangement, CRA stated: In a situation where an employer pays money to a bank, trust company or broker to meet its obligations upon the retirement of an employee, the money could be considered a contribution in respect of benefits that may be received by a person upon that person's retirement. … Please note that the definition of a retirement compensation arrangement does not require that the contributions become the property of the person to whom they are made or that a trust be created. ...

22 March 2005 External T.I. 2005-0112081E5 F - Convention de retraite - lettre de crédit -- summary under Refundable Tax

22 March 2005 External T.I. 2005-0112081E5 F- Convention de retraite- lettre de crédit-- summary under Refundable Tax Summary Under Tax Topics- Income Tax Act- Section 207.5- Subsection 207.5(1)- Refundable Tax use of letter of credit to secure RCA benefits The employer for an RCA trust contributed to it an amount equaling the fee payable by the trust to a financial institution for issuing a letter of credit, plus the (equal) amount of the refundable tax. ...

22 March 2005 External T.I. 2005-0112081E5 F - Convention de retraite - lettre de crédit -- summary under Subsection 207.5(2)

22 March 2005 External T.I. 2005-0112081E5 F- Convention de retraite- lettre de crédit-- summary under Subsection 207.5(2) Summary Under Tax Topics- Income Tax Act- Section 207.5- Subsection 207.5(2) election not available to custodian holding an LC The employer for an RCA trust contributed to it an amount equaling the fee payable by the trust to a financial institution for issuing a letter of credit, plus the (equal) amount of the refundable tax. ...

29 May 2007 Internal T.I. 2006-0217401I7 F - 110(1)d): Moment de la conclusion de la convention -- summary under Subsection 7(5)

29 May 2007 Internal T.I. 2006-0217401I7 F- 110(1)d): Moment de la conclusion de la convention-- summary under Subsection 7(5) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(5) not giving exercise notice to employees who are not shareholders (so that they cannot exercise their options) may engage s. 7(5) Employees of Opco (Participants”) were granted stock options by Opco pursuant to “Grant Agreements” which specified the number of Options granted and their exercise price (which equaled the FMV of the subject shares at the time of such grant), but provided that such Options were not exercisable (and could not be surrendered to Opco for their cash surrender value) until the compensation committee of Opco had issued an “Exercise Notice” to the Participant. ...

22 March 2005 External T.I. 2005-0112081E5 F - Convention de retraite - lettre de crédit -- summary under Subsection 207.7(2)

22 March 2005 External T.I. 2005-0112081E5 F- Convention de retraite- lettre de crédit-- summary under Subsection 207.7(2) Summary Under Tax Topics- Income Tax Act- Section 207.7- Subsection 207.7(2) where LC used to secure RCA benefits and refundable tax generated on funding of LC fees, refundable tax not recoverable based on paying the benefits The employer for an RCA trust contributed to it an amount equaling the fee payable by the trust to a financial institution for issuing a letter of credit, plus the (equal) amount of the refundable tax. ...

Healthlease -- summary under Cross-Border REITs

It should be eligible for benefits under the Canada-US Convention provided that its units are primarily and regularly traded on the TSX. Interest on the notes of HealthLease US held by the REIT (which should be characterized as debt rather than equity based on certain interest rate and debt feasibility studies) should be exempt from US withholding tax under the Convention. ...

Stéphane Austry, John Avery Jones, Philip Baker, Peter Blessing, Robert Danon, Shefali Goradia, Koichi Inoue, Jürgen Lüdicke, Guglielmo Maisto, Toshio Miyatake, Angelo Nikolakakis, Kees van Raad, Richard Vann, Bertil Wiman, "The Proposed OECD Multilateral Instrument Amending Tax Treaties", Bulletin for International Taxation, December 2016, p. 683 -- summary under Income Tax Conventions

It would be necessary to turn to the MLI for the wording of the modifying provision and to read the bilateral convention along with, and as modified by, the MLI. Thus, rather than seeking to delete and replace wording in existing bilateral conventions, within the scope of matters covered by the MLI, one would turn from the bilateral convention to the MLI for the relevant wording. ... That task is relatively easy where the bilateral convention is based upon the OECD Model or UN Model, but as far harder task where the wording departs from either of those Models. ...

Baxter, Double Taxation Agreements and International Tax Law, Sweet Maxwell (London, 1991). -- summary under Income Tax Conventions

.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions ...

Michael Lang, "Income Allocation Issues Under Tax Treaties", Tax Notes International, April 21, 2014, p. 285. -- summary under Income Tax Conventions

.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions No implications of specific safe harbours (p. 287) Therefore, a special provision is no indication that something else applies outside its explicitly defined scope of application. ... Relevance of subsequent OECD Commentary (p. 289) The differentiated reasoning adopted by the court, however, is not very conclusive: "A later OECD Commentary should only be of assistance if not in conflict with the Commentary in existence at the time of the Convention." ...

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