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...
12 May 1999 External T.I. 9908085 F - RPA- RACHAT DE SERVICES PASSÉS
An individual can deduct contributions paid for services rendered before 1990 and after 1989, even if they are determined and paid when the former...
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 |