Words and Phrases - "bonds, notes, debentures or similar obligations"
17 April 2014 External T.I. 2012-0461151E5 F - pension fund real estate
Summary Under
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(o.2) - Subparagraph 149(1)(o.2)(iii)advance from RPP shareholder is permitted if not evidenced by issuance of debenture etc.
Would an advance made by a registered pension plan ("RPP") to a pension plan investment corporation (“PPIC”) wholly owned by it qualify under s. 149(1)(o.2)(iii)(B)? CRA responded (TaxInterpretations translation):
[W]here an advance paid by an RPP to a PPIC is not evidenced by the issuance of a bond, note, debenture or similar obligation, we are of the view that that advance complies with the condition in clause 149(1)(o.2)(iii)(B). As required by the preamble in subparagraph 149(1)(o.2)(iii), such advance must in addition be permitted under the Pension Benefits Standards Act, 1985 or a similar law of a province.
Words and Phrases
bonds, notes, debentures or similar obligations