30 June 1999 External T.I. 9911555 F - CR POUR ACTIONNAIRE-DIRIGEANT -- attach -- Salary Deferral Arrangement
foregoing by a shareholder-officer of significant salary in exchange for an RCA contribution, may be an SDA
Salary Deferral Arrangement
Martin v. The King, 2024 TCC 153 -- attach -- Salary Deferral Arrangement
taxpayers' RCAs were not SDAs because they provided for reasonable pensions
2021 Ruling 2021-0887611R3 - Defined Contribution SERP -- attach -- Salary Deferral Arrangement
SERP providing for lump sum or 10 annual instalments on retirement is not an SDA
24 May 2002 Internal T.I. 2002-0130667 F - REGIME PRESTATION EMPLOYES -- attach -- Salary Deferral Arrangement
discussion of transitional rules re expansion of SDA rules effective February 26, 1986
7 March 2022 External T.I. 2021-0895571E5 - Clarification of Comments in 2020-086483 -- attach -- Salary Deferral Arrangement
an RSU award as signing bonus or inducement to move, or as an award for a current performance accomplishment. might not engage the SDA rules
3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 6, 2023-0994241C6 F - Consequences of Transfer of DSUs to a corporation -- attach -- Salary Deferral Arrangement
transfer of DSU to corporation would cause it to cease to qualify, perhaps retroactively
19 October 2004 External T.I. 2004-0085561E5 F - Régime de droit à la plus-value des actions -- attach -- Salary Deferral Arrangement
right under phantom plan to receive the appreciation, on employment termination, as an annuity could engage the SDA rules
24 January 2005 External T.I. 2004-0099471E5 F - Convention de retraite pour un actionnaire-employé -- attach -- Salary Deferral Arrangement
a significant reduction in bonus or salary matched by an RCA contribution likely suggests it instead is an SDA
2 February 2005 External T.I. 2004-0104671E5 F - Convention de retraite - Fonds mis de côté -- attach -- Salary Deferral Arrangement
amounts agreed to be paid post-retirement do not create an SDA if they are not reasonably regarded as deferred salary
12 April 2005 External T.I. 2005-0121251E5 F - Temps supplémentaire accumulé -- attach -- Salary Deferral Arrangement
question of fact whether ability of employees to bank their overtime was an SDA
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