Section 147.2

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...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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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...

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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