Words and Phrases - "pension"
23 February 2001 External T.I. 2001-0066265 F - Salaire différé français
receipt of “deferred salary,” pursuant to a right established by French legislation, was not a pension given no previous employer-employee relationship
A French citizen residing in Canada had helped to run the family farm in France and, to thank him for those seven years of contribution, his...
Words and Phrases
pensionLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) | receipt of “deferred salary,” pursuant to a right established by French legislation, as compensation for contribution to the family farm was not income | 311 |
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (b) - Subparagraph (b)(ii) | receipt of “deferred salary,” pursuant to a right established by French legislation, was not a pension given no previous employer-employee relationship | 306 |
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | “deferred salary” right of farmer descendant was a debt | 82 |
6 April 2023 Internal T.I. 2022-0929731I7 - Articles 18(2) and (3) of the Canada-Italy Treaty
CPP and OAS payments treated as pensions and social security payments under the Canada-Italy Treaty
Regarding the receipt by an individual resident in Italy of periodic Canada Pension Plan (“CPP”) and Old Age Security (“OAS”) benefit...
Words and Phrases
pensionLocations of other summaries | Wordcount | |
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Tax Topics - Other Legislation/Constitution - Federal - Income Tax Conventions Interpretation Act - Section 5 | CPP and OAS are normally considered pensions for Treaty purposes | 90 |
31 July 2002 Internal T.I. 2002-0136937 F - Placement Français "Assurance-salaire-vie
withdrawal from French employee-contribution plan (assurance-salaire-vie) was not a “pension”
The holder in France of an "assurance-salaire-vie," which is similar to a registered retirement savings plan except that a withdrawal from it is...
Words and Phrases
pensionLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 233.3 - Subsection 233.3(1) - Reporting Entity | cost amount of foreign retirement plan may have been stepped up under s. 128.1(1) | 68 |