Subsection 207.6(2) - Life insurance policies
Administrative Policy
14 January 2004 External T.I. 2003-0046131E5 F - Convention de retraite - dépositaire
After indicating that a life insurance company can be a custodian of a "retirement compensation arrangement" (“RCA”), CRA went on to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retirement Compensation Arrangement | life insurance company can be a custodian | 115 |
10 January 2002 External T.I. 2001-0112885 F - ASSURANCE-VIE ET PRET REMBOURSE AU DECES
CCRA provided the following overview of the use of a life insurance policy to fund an RCA:
[W]here an employer acquires an interest in a life...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Policy Loan | GAAR could apply where a life insurance policy is pledged for a loan that is not required to be repaid until after death | 84 |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | benefit may result from pledging a corporate asset to secure a personal loan | 64 |
1 May 1991 T.I. (Tax Window, No. 3, p. 11, ¶1227)
Part XI.3 applies where a corporation purchases a life annuity in order to provide additional retirement income to an employee. The corporation...
17 April 1991 T.I. (Tax Window, No. 2, p. 20, ¶1205)
Where the employer wishes to withdraw funds from insurance policies which have been acquired by the custodian of an employee benefit plan where...
8 September 89 T.I. (February 1990 Access Letter, ¶1125)
An employer purchased an exempt life insurance policy on the lives of the employees, one of the employees died and the benefit under the policy...
88 C.R. - Q.30
S.207.6(2) extends to the purchase of an insurance policy to fund an obligation to pay retiring allowances where the employer is the owner of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 207.5 - Subsection 207.5(1) - Refundable Tax | 14 |
Articles
Holmes, "Life Insurance Proceeds May Be Taxable Where a Policy is Used to Fund Supplemental Retirement Plan", Taxation of Executive Compensation and Retirement, May 1990, p. 275.
Paragraph 207.6(2)(d)
Administrative Policy
10 October 2003 Roundtable, 2003-0037145 F - CONVENTION DE RETRAITE
Where an employer funds retirement benefits under a retirement compensation plan by acquiring a life insurance policy and designating the employee...
Subsection 207.6(4) - Deemed contribution
Administrative Policy
14 November 89 T.I. (April 90 Access Letter, ¶1185)
Where there is a provision in an employee benefit plan for a change of trustee and the new trustee is resident in Canada, this change in trustee...
Subsection 207.6(5) - Residents’ arrangement
Administrative Policy
3 December 1997 External T.I. 9715195 - FOREIGN PENSION PLAN
General discussion of contributions to a foreign pension plan.
Articles
Jim Kahane, Uros Karadzic, Simon Létourneau-Laroche, "A Fresh Look at Retirement Compensation Arrangement: A Flexible Vehicle for Retirement Planning", Canadian Tax Journal (2013) 61:2, 479 – 502.
Resident contribution rule (p. 491)
Under these rules, if a newcomer to Canada remains a member of his or her home-country pension plan for more...
Subsection 207.6(5.1)
Administrative Policy
2021 Ruling 2021-0876671R3 - Transfer between US pension plans
S. 56(1)(a) generally requires the recognition of an amount received as or in satisfaction of a pension benefit. A portion of a multi-employer US...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) | the transfer of a portion of the assets and Canadian beneficiaries from an old to a new US pension plan did not result in receipt under s. 56(1)(a) | 466 |
| Tax Topics - General Concepts - Payment & Receipt | no constructive receipt to Canadian beneficiaries where the transfer of a portion of the assets and Canadian beneficiaries from an old to a new US pension plan | 109 |
| Tax Topics - Treaties - Income Tax Conventions - Article 18 | the transfer of a portion of the assets and beneficiaries from an old to a new US pension plan did not result in taxable income under the IRC | 183 |
Subsection 207.6(7)
Administrative Policy
2019 Ruling 2019-0803761R3 - New RCA to replace benefits under existing RCA
CRA ruled that a new supplemental pension plan would qualify as a retirement compensation arrangement and that s. 207.6(7) would apply to the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retirement Compensation Arrangement | new RCA trust permits the retired employee to request an immediate payout on “a material deterioration in the Canadian economy” | 451 |