Employee Benefit Plan

Cases

MNR v. Chrysler Canada Ltd., 92 DTC 6346 (FCTD)

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Re MNR and Chrysler Canada Ltd., 91 DTC 5526 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 7 - Subsection 7(2) oral agreement 170

See Also

Bedard v. MNR, 91 DTC 573 (TCC)

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Crighton v. MNR, 91 DTC 511 (TCC)

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Administrative Policy

1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) no s. 7(3)(b) prohibition where at employer’s option to settle PSPs in cash or in shares 230
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) s. 7 rules do not apply to shares purchased through a trust 166
Tax Topics - Income Tax Act - Section 32.1 - Subsection 32.1(1) payments made by Canco to parent for the value of parent shares distributed by parent-funded EBP to Canco employees were not deductible under s. 32.1 259
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose recharge payments made for employees participating in parent-administered PSP not deductible to extent they were employed by affiliates during vesting period 233
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) request for deduction not to be allowed if based on case decision rather than error 259

S2-F1-C1 - Health and Welfare Trusts

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2013 Ruling 2012-0470801R3 - Employee Benefit Plan - Redemption Window

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23 February 1995 Internal T.I. 7-942508 -

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23 January 1992 External T.I. 5-913366 -

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21 October 1991 T.I. (Tax Window, No. 11, p. 5, ¶1532)

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10 June 1991 T.I. (Tax Window, No. 4, p. 28, ¶1293)

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12 January 1990 T.I. (June 1990 Access Letter, ¶1248)

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Articles

Simon Thompson, "Canada's Income Tax Rules for Non-Registered Plans: Implications for Foreign Pensions", A Journal of International Taxation, Vol. 15, No. 10, October 2004, p. 34.

D. Bruce Ball, Brenda Dietric H., "Canadian Taxation of Foreign Pensions", Personal Tax Planning, 2000 Canadian Tax Journal, Vol. 48, No. 6, p. 1908.

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