Income Tax Act — I-3.3 207.5
Definitions 207.5 (1) In this Part, advantage , in relation to a retirement compensation arrangement, means (a) any benefit, loan or indebtedness that is conditional in any way on the existence of the arrangement, other than (i) a benefit derived from the provision of administrative or investment services in respect of the arrangement, (ii) a loan or an indebtedness the terms and conditions of which are terms and conditions that persons dealing at arm’s length with each other would have entered into, and (iii) a payment out of or under the arrangement that is included in computing a taxpayer’s income under Part I, and (b) a benefit that is an increase in the total fair market value of the subject property of the arrangement if it is reasonable to consider, having regard to all the circumstances, that the increase is attributable, directly or indirectly, to a transaction or event or a series of transactions or events one of the main purposes of which was to enable a person or a partnership to benefit from a provision of this Part, or from the exemption from tax under paragraph 149(1)(q.1), if the transaction, event or series (i) would not have occurred in a normal commercial or investment context in which parties deal with each other at arm’s length and act prudently, knowledgeably and willingly, or (ii) included a payment received as, on account or in lieu of, or in satisfaction of, a payment (A) for services provided by a person who is, or does not deal at arm’s length with, a specified beneficiary of the arrangement, or (B) of interest, of a dividend, of rent, of a royalty or of any other return on investment, or of proceeds of disposition, in respect of property (other than subject property of the arrangement) held by a person who is, or does not deal at arm’s length with, a specified beneficiary of the arrangement, (c) a benefit that is income or a capital gain that is reasonably attributable, directly or indirectly, to (i) a prohibited investment in respect of the arrangement, (ii) an amount received by a specified beneficiary of the arrangement, or by a person who does not deal at arm’s length with the specified beneficiary, if it is reasonable to consider, having regard to all the circumstances, that the amount was paid in relation to, or would not have been paid but for, subject property of the arrangement and the amount was paid as, on account or in lieu of, or in satisfaction of, a payment (A) for services provided by a person who is, or who does not deal at arm’s length with, the specified beneficiary, or (B) of interest, of a dividend, of rent, of a royalty or of any other return on investment, or of proceeds of disposition, (d) an RCA strip in respect of the arrangement, and (e) a prescribed benefit; ( avantage ) excluded contribution means an amount paid or payable under a specified arrangement to obtain or renew a letter of credit or surety bond issued by a financial institution for the purposes of securing future retirement benefit payments out of or under the arrangement; ( cotisation exclue ) prohibited investment , for a retirement compensation arrangement at any time, means property (other than prescribed excluded property) that is at that time (a) a debt of a specified beneficiary of the arrangement, (b) a share of the capital stock of, an interest in, or a debt of (i) a corporation, partnership or trust in which the specified beneficiary has a significant interest, or (ii) a person or partnership that does not deal at arm’s length with, or is affiliated with, the specified beneficiary, (c) an interest (or, for civil law, a right) in, or a right to acquire, a share, interest or debt described in paragraph (a) or (b), or (d) prescribed property; ( placement interdit ) RCA strip , in respect of a retirement compensation 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 transact