Income Tax Act — I-3.3 207.5
ensation arrangement, means the amount of a reduction in the fair market value of subject property of the arrangement, if the value is reduced as part of a transaction or event or a series of transactions or events one of the main purposes of which is to enable a specified beneficiary of the arrangement, or a person or a partnership who does not deal at arm’s length with the specified beneficiary, to benefit from a provision of this Part or to obtain a benefit in respect of subject property of the arrangement or as a result of the reduction, but does not include an amount that is included in computing the income of the specified beneficiary or of an employer or former employer of the specified beneficiary; ( somme découlant d’un dépouillement de CR ) RCA trust under a retirement compensation arrangement means (a) any trust deemed by subsection 207.6(1) to be created in respect of subject property of the arrangement, and (b) any trust governed by the arrangement; ( fiducie de convention de retraite ) refundable tax of a retirement compensation arrangement at the end of a taxation year of an RCA trust under the arrangement means the amount, if any, by which the total of (a) 50% of all contributions (other than an excluded contribution made on or after March 28, 2023) made under the arrangement while it was a retirement compensation arrangement and before the end of the year, and (b) 50% of the amount, if any, by which (i) the total of all amounts each of which is the income (determined as if this Act were read without reference to paragraph 82(1)(b)) of an RCA trust under the arrangement from a business or property for the year or a preceding taxation year or a capital gain of the trust for the year or a preceding taxation year, exceeds (ii) the total of all amounts each of which is a loss of an RCA trust under the arrangement from a business or property for the year or a preceding taxation year or a capital loss of the trust for the year or a preceding taxation year, exceeds (c) 50% of all amounts paid as distributions to one or more persons (including amounts that are required by paragraph 12(1)(n.3) to be included in computing the recipient’s income) under the arrangement while it was a retirement compensation arrangement and before the end of the year, other than a distribution paid where it is established, by subsequent events or otherwise, that the distribution was paid as part of a series of payments and refunds of contributions under the arrangement; ( impôt remboursable ) significant interest has the same meaning as in subsection 207.01(4); ( participation notable ) specified arrangement means a retirement compensation arrangement of which the primary purpose is to provide annual or more frequent periodic retirement benefit payments that are paid (a) as supplemental benefits provided out of or under (i) a registered pension plan, (ii) a registered retirement savings plan, (iii) a deferred profit sharing plan, (iv) a pooled registered pension plan, or (v) any combination of plans described in subparagraphs (i) to (iv), or (b) under an arrangement that would, in the absence of subsection 147.1(8) and section 8504 of the Income Tax Regulations , substantially comply with the prescribed conditions for registration for a registered pension plan under section 8501 of those Regulations; ( convention déterminée ) specified beneficiary , of a retirement compensation arrangement, means an individual who has an interest or a right in respect of the arrangement and who has or had a significant interest in an employer or former employer in respect of the arrangement; ( bénéficiaire déterminé ) subject property of a retirement compensation arrangement means property that is held in connection with the arrangement. ( bien déterminé d’une convention de retraite ) Election (2) Despite the definition refundable tax in subsection 207.5(1), where the custodian of a retirement compensation arrangement so elects in the return under this Part