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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 147.1 - Subsection 147.1(1) - Participating Employer | 99 | |
| Tax Topics - Income Tax Act - Section 147.2 - Subsection 147.2(8) | 123 |
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 147.1 - Subsection 147.1(5) | 589 | |
| Tax Topics - Income Tax Regulations - Regulation 8515 - Subsection 8515(1) | 158 |
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 | income is to be computed on a “sub-source” basis | 117 |
| Tax Topics - Statutory Interpretation - Headings | heading provided guidance on the overall framework | 236 |
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,...
10 May 2000 Internal T.I. 2000-0016257 F - RPA COTISATIONS POUR SERVICES ANTERIEURS
A retroactive deduction could not be generated for contributions to an RPP relating to past service.
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) | 98(5) wind-up through s. 85 transfer of partnership interest of one partner to the other and preceded by debt assumptions | 292 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) | interest deductible following assumption of interest-bearing internal debt on s. 98(5) wind-up | 297 |
| Tax Topics - Income Tax Act - Section 34.2 - Subsection 34.2(11) | continuation of s. 34.2(11) reserve following partnership wind-up | 339 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | continued availability of s. 20(1)(m) reserve following s. 98(5) wind-up | 296 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) | flow-through of s. 20(1)(n) reserve on s. 98(5) wind-up | 289 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(24) | s. 20(24) election on s. 98(5) wind-up | 307 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) | s. 18(9) deduction claimable by transferee former partner following s. 98(5) wind-up | 241 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(i) | no income inclusion on assumption on s. 98(5) wind-up of DSUs and RSUs | 356 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement - Paragraph (k) | no income on RSU/DSU assumption | 22 |