Subsection 147(1) - Definitions
Deferred Profit Sharing Plan
Administrative Policy
8 November 2004 Internal T.I. 2004-0093441I7 - DPSP - Contributions Based on US Parent's Profits
An employer could base its contributions solely on the profits of its U.S. parent.
Profit Sharing Plan
Administrative Policy
20 January 2005 External T.I. 2004-0104921E5 F - RPDB et déficit cumulé
Regarding whether a profit sharing plan can be registered as a DPSP when the corporation has an accumulated deficit, CRA indicated, yes, s. 147...
Subsection 147(2) - Acceptance of plan for registration
Administrative Policy
27 October 1994 T.I. 942454 (C.T.O. "Profit Sharing Plan for Corporate Partner")
Where a corporation controls a partnership which in turn owns all the shares of an employer, the corporate partner will not be considered to deal...
8 December 1993 External T.I. 9332125 F - HAA 7209-1 Division of DPSP on Marriage Breakdown
Funds in an DPSP cannot be split on a marriage breakdown given the prohibition against assignment in s. 147(2)(e). If funds are paid directly to a...
19 November 1992 Memorandum 923036 (September 1993 Access Letter, p. 424, ¶C144-240)
Although a pension plan could have two separate trusts relating to two sets of defined benefit provisions, if the plan was adequately funded an...
21 September 1992 T.I. (Tax Window, No. 24, p. 22, ¶2205)
Where contributions are made by a Canadian employer to a registered pension plan in respect of an employee who has moved to the United States but...
IC 77-1R5 "Deferred Profit Sharing Plans"
Paragraph 147(2)(k)
Administrative Policy
27 April 2009 External T.I. 2008-0304761E5 F - Retraits et transferts provenant d'un RPDB
Regarding what amounts DPSP members may withdraw, either in whole or in part, from the DPSP while remaining employed by the employer, CRA...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 147 - Subsection 147(19) | s. 147(19) available even while member still an employee | 236 |
Subsection 147(8) - Amount of employer’s contribution deductible
Administrative Policy
3 May 2002 External T.I. 2002-0132615 F - PERTE DECOULANT D'UN PAIEMENT A UN RPDB
Would an employer's contribution to a DPSP be deductible from income even if the contribution resulted in a business loss, for example, a taxpayer...
20 January 1994 External T.I. 9400755 - EBP'S, EPSP'S, DPSP'S AND SECTION 7
Even if a deferred profit sharing plan can be considered primarily "an agreement to issue shares", the treatment under s. 147 is more specific...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 32.1 - Subsection 32.1(1) | 43 |
Subsection 147(10) - Amounts received taxable
Cases
The Queen v. Powell, 80 DTC 6301, [1980] CTC 382 (FCTD)
When a beneficiary elected to close out his account the "amounts received" by him included, under the broad meaning of that phrase, shares of...
Subsection 147(10.1)
Administrative Policy
IT-363R2 (Cancelled) – Deferred Profit Sharing Plans – Deductibility of Employer Contributions and Taxation of Amounts Received by a Beneficiary 28 May 1993
14. A DPSP beneficiary may receive a single payment under the plan from the trustee for the termination of an interest in the plan. This...
Subsection 147(10.3)
Administrative Policy
19 May 2011 External T.I. 2011-0405431E5 F - RPDB et feuillet T4
In the course of a general discussion, and after describing the persons referenced in s. 147(2)(k.2) who came within the ambit of s. 147(10.3),...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | no T4 reporting for employer DPSP contribution | 110 |
| Tax Topics - Income Tax Regulations - Regulation 8301 - Subsection 8301(2) | T4 reporting by DPSP employer of pension adjustment | 169 |
Subsection 147(19)
Administrative Policy
27 April 2009 External T.I. 2008-0304761E5 F - Retraits et transferts provenant d'un RPDB
Regarding what amounts DPSP members may withdraw, either in whole or in part, from the DPSP while remaining employed by the employer, CRA...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 147 - Subsection 147(2) - Paragraph 147(2)(k) | s. 147(2)(k) available even while member still an employee | 99 |