Subsection 147.2(1) - Pension contributions deductible — employer contributions
See Also
Patons & Baldwins Ltd. v. MNR, 69 DTC 189, [1969] Tax A.B.C. 221
S.11(1)(g) of the pre-1972 Act was found to preclude the deduction of annual contributions to an unregistered pension plan under the general law...
Administrative Policy
6 May 1991 T.I. (Tax Window, No. 3, p. 12, ¶1241)
Where a corporation contributes treasury shares, an amount equal to their fair market value would normally be deductible by the corporation.
Subsection 147.2(2) - Employer contributions — defined benefit provisions
Administrative Policy
30 November 1995 Ruling 9636543 - 147.2(2) EMPLOYEE OF PREDECESSOR
An employer may take a deduction under s. 147.2(2) with respect to employees of a predecessor employer.
18 June 1992 Internal T.I. 7-921699
General discussion.
new item
Paragraph 147.2(2)(a)
Subparagraph 147.2(2)(a)(vi)
Administrative Policy
Actuarial Bulletin No. 4 - Draft Bulletin for Industry Consultation "Reasonable Methods to Apportion Assets and Actuarial Liabilities" 8 January 2020
Subject of Bulletin
This bulletin gives guidelines and examples of reasonable methods to apportion assets and actuarial liabilities for the...
paragraph 147.2(2)(d)
Administrative Policy
Newsletter 21-1, Additional Conditions Applicable to Individual Pension Plans and Designated Plans, 16 March 2021
Effective prohibition of the avoidance of contribution holidays through using hybrid defined benefit/money purchase provisions
- Some employers who...
Subsection 147.2(4) - Amount of employee’s pension contributions deductible
See Also
Smith v. The Queen, 2018 TCC 61 (Informal Procedure)
In his 2015 taxation year, the taxpayer (a status Indian) received $37,800 in exempt employment income from the Tlowitsis‑Mumtagila First...
Administrative Policy
26 November 2013 External T.I. 2013-0498601E5 - Voluntary contribution to U.K. Pension
The resident taxpayer, who had emigrated from the U.K., could not deduct a "top-up" contribution to a U.K. pension plan in determining taxable...
21 July 1992 Internal T.I. 5-922117
Discussion of situation arising out of a federal government employee going to another employer before the employee has fully paid the cost of...
Paragraph 147.2(4)(a) - Service after 1989
Administrative Policy
12 July 2007 Internal T.I. 2007-0240681I7 F - Indiens - Cotisations à un RPA
During his 2006 taxation year, when only a portion of his income was exempt under s. 87 of the Indian Act, the taxpayer made past service...
Paragraph 147.2(4)(c)
Administrative Policy
27 June 2003 External T.I. 2003-0019095 F - RACHAT DE SERVICES PASSES
An employee had been contributing for some time to an RPP, but during a period from 1986 to 1988, no contributions were made to an RPP. CCRA...
21 November 2001 External T.I. 2001-0104785 F - CONTRIBUTION A UN RPA SERVICES PASSES
A taxpayer, who had been a member of his employer's registered pension plan since 1980, was on leave without pay from July 1, 1985 to July 1,...
Subsection 147.2(8)
Administrative Policy
Actuarial Bulletin No. 4 - Draft Bulletin for Industry Consultation "Reasonable Methods to Apportion Assets and Actuarial Liabilities" 8 January 2020
Monitoring compliance with continuity rules
[S]ubsection 147.2(8) ... deems former employees of a vendor to be employees of a participating...
2015 Ruling 2015-0601441R3 - XXXXXXXXXX Partnership - winding up
Current structure
Sub1 and Sub2 (both taxable Canadian corporations and wholly-owned subsidiaries of Parent) are currently the sole partners of a...