Section 207.6

Subsection 207.6(2) - Life insurance policies

Administrative Policy

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...

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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...

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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...

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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...

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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.

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...

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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...

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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...

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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...

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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