Section 147.2

Subsection 147.2(1) - Pension contributions deductible — employer contributions

See Also

Patons & Baldwins Ltd. v. MNR, 69 DTC 189, [1969] Tax A.B.C. 221

S.11(1)(g) of the pre-1972 Act was found to preclude the deduction of annual contributions to an unregistered pension plan under the general law relating to deductions by commercial enterprises.

Administrative Policy

6 May 1991 T.I. (Tax Window, No. 3, p. 12, ¶1241)

Where a corporation contributes treasury shares, an amount equal to their fair market value would normally be deductible by the corporation.

Subsection 147.2(2) - Employer contributions — defined benefit provisions

Administrative Policy

1996 Ruling 963654 (C.T.O. "Employee of Predecessor")

An employer may take a deduction under s. 147.2(2) with respect to employees of a predecessor employer.

Subsection 147.2(4) - Amount of employee’s pension contributions deductible

Administrative Policy

26 November 2013 T.I. 2013-0498601E5 - Voluntary contribution to U.K. Pension

top-up contribution to UK plan

The resident taxpayer, who had emigrated from the U.K., could not deduct a "top-up" contribution to a U.K. pension plan in determining taxable income for Canadian tax purposes, as contributions to a pension plan are only deductible in computing a Canadian resident's taxable income where the pension plan is registered, and "a U.K. pension plan does not satisfy the definition of a registered pension plan."

21 July 1992 Memorandum 5-922117

Discussion of situation arising out of a federal government employee going to another employer before the employee has fully paid the cost of buying back past service.

Paragraph 147.2(4)(a) - Service after 1989