Cases
Pension Plan for Presidents of 1398874 Ontario Inc. v. Canada (National Revenue), 2010 DTC 5030 [at 6634], 2010 FCA 14
The taxpayer was incorporated by a retiring police officer to set up an individual pension plan, into which he transferred the commuted value of...
Administrative Policy
23 July 1992 Internal T.I. 7-921856
The controlling shareholders of corporations that collectively formed a partnership would be entitled to be members of a defined benefit plan...
Paragraph 8502(a) - Primary Purpose
See Also
Ross v. The Queen, 2013 DTC 1250 [at 1400], 2013 TCC 333
In 2001, the first taxpayer transferred the commuted value of his entitlements under his registered pension plan with OMERS to a new pension plan...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | misrepresentation must be in return | 161 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01) | 371 |
Paragraph 8502(c) - Permissible Benefits
Administrative Policy
26 April 1994 Internal T.I. 9409486 - RPP PAYMENTS TO BENEFICIARIES AS PRIZES OR BENEFITS
Prizes paid to beneficiaries in order to induce them to purchase past service represent distributions described in Regulation 8502(d) and benefits...
Paragraph 8502(i)
Administrative Policy
15 June 2020 External T.I. 2020-0850981E5 - CECRA – Pension plan eligibility
The CECRA program contemplates the making of loans to commercial landlords to partially fund their providing rent relief to qualifying tenants,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(o.2) - Subparagraph 149(1)(o.2)(ii) - Clause 149(1)(o.2)(ii)(C) | CECRA loans give rise to income from real property and thus are not a disqualified borrowing | 241 |
10 May 2016 Internal T.I. 2016-0644761I7 - RPP borrowing
As the amount of borrowing in respect of certain real estate properties of a pension plan exceeded their cost, the Directorate considered “that...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(o.2) - Subparagraph 149(1)(o.2)(iii) | 149(1)(o.2)(ii) corp. could incur purchase price indebtedness on internal transfer in excess of vendor’s cost | 161 |
Articles
Hersh Joshi, Jack Silverson, "Understanding and Doing Business with Tax-Exempt Entities", 2018 Conference Report (Canadian Tax Foundation), 29:1 – 35
Potential for deemed loan JV provisions to constitute borrowing ((p. 29-4)
Many joint venture agreements contain a clause providing that if one of...