Words and Phrases - "constructive receipt"
14 May 2012 Internal T.I. 2010-0367831I7 F - Régime de pension étranger. France
contributions paid by employer to voluntary French pension funds for expatriates were constructively received by employee member
Contributions were paid by the employer of a Canadian resident of French nationality to the Caisse de retraite pour la France et l’Extérieur...
Words and Phrases
constructive receiptLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retirement Compensation Arrangement | since employer acted as employee agent in making pension contributions, no RCA, EBP or SDA | 73 |