Article 18

Cases

Korfage v. The Queen, 2016 TCC 69

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) pension income deduction arose when each pension payment was received, translated at annual average 322

Rodrigue v. The Queen, 2001 DTC 5296, 2001 FCA 157

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See Also

Dumoulin v. The Queen, 2003 DTC 872 (TCC)

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Merrins v. The Queen, 2002 DTC 1848, Docket: 2001-304-IT-I (TCC)

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Levert v. The Queen, 2001 DTC 781, Docket: 1999-566-IT-I (TCC)

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Coblentz v. The Queen, 96 DTC 6531 (FCA.)

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Tax Topics - Treaties 21

Administrative Policy

22 February 2016 External T.I. 2014-0525681E5 - Taxation of inherited pension plan payment

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Superannuation or Pension Benefit pension paid to beneficiary of deceased employee was pension rather than death benefit 284
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit payment out of a pension plan to a beneficiary of deceased employee was a pension rather than death benefit payment 74

3 October 2014 External T.I. 2013-0509751E5 - RRSP or RRIF payments to a resident of New Zealand

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26 September 2014 External T.I. 2014-0531441E5 - Unfunded LTD plan payment to non-resident employee

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 115 - Subsection 115(2) - Paragraph 115(2)(c) employee long-term disability payments: remuneration under ITA; pension under Cda-U.S. Convention 206
Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) employee long-term disability payments: remuneration under ITA; pension under Cda-U.S. Convention 206

13 May 2014 External T.I. 2014-0525491E5 - Emigration to Poland - Various tax considerations

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6 September 2013 External T.I. 2013-0478241E5 - U.K. Individual Savings Account (ISA)

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12 March 2013 External T.I. 2013-0476351E5 - Taxation of Roth IRA

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30 January 2013 External T.I. 2012-0449621E5 F - Belgian pension

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17 October 2012 External T.I. 2012-0438671E5 - Treatment of German social security pension

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25 June 2012 External T.I. 2011-0398691E5 - Conversion of U.S. Traditional IRA into Roth IRA

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25 June 2012 External T.I. 2011-0404071E5 - Election to defer income in U.S. traditional IRA

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12 June 2012 External T.I. 2012-0432281E5 - Foreign pension plan

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24 April 1997 T.I. 970538

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20 June 1996 T.I. 961204

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29 April 1996 T.I. 961448 (C.T.O. "Part XIII - RRSP of Deceased Non-Resident")

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1995 TEI Round Table, Q. 17 (Draft) (953051) (C.T.O. "Is a Retirement Compensation Arrangement a 'Pension' for Purposes of Canada-U.S.Treaty?")

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20 October 1994 T.I. 941658 (C.T.O. "Is RRIF Payment to U.K. Resident a Pension? (U4-100-17)")

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22 September 1994 T.I. 941180 (C.T.O. "Retiring Allowance Paid to U.K. Resident (U4-100-17)")

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31 March 1994 T.I. 933999 (C.T.O. "RRIF - Periodic Pension Payment - U.S. Convention (U5-100-18)")

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24 March 1994 T.I. 933575 (C.T.O. "RRIF Paid to UK Resident - Pension & Annuity (U4-100-17)")

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93 C.R. - Q. 32

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7 February 1994 T.I. 940135 (C.T.O. " U.S. Pension Received by Canadian (4093-U5-100-18)")

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27 February 1992 T.I. (Tax Window, No. 17, p. 18, ¶1767)

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20 November 1991 T.I. (Tax Window, No. 13, p. 8, ¶1601)

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7 October 1991 T.I. (Tax Window, No. 10, p. 22, ¶1500)

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2 August 1991 T.I. (Tax Window, No. 8, p. 23, ¶1420)

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6 March 1991 Memorandum (Tax Window, No. 1, p. 18, ¶1148)

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88 C.R. - Q.1

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88 C.R. - Q.5

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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.

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Kevyn Nightingale, David Turchen, "The US Tax Implications of a Tax-Free Savings Account", CCH Tax Topics, No. 2146, April 25, 2013, p.1, at 2

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Faizal Valli, "Implications of Canadians Transferring a U.S. Retirement Plan to Canada", Taxation of Executive Compensation and Retirement, Vol. XV, No. 2, 2011, p. 930.

Finley, "Payments Out of a RCA May Not Be Eligible for Reduced Withholding Tax", Taxation of Executive Compensation and Retirement, September 1990, p. 327

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