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IPP Contributions

Deductibility of Company Contributions

Since an IPP is a defined benefit pension plan, the deductibility of Company contributions is governed by Sections 147.2(1) and 147.2(2) of the Income Tax Act.

Under Subsection 147.2(1) of the Income Tax Act, an employer contribution to a registered defined benefit pension plan is deductible in computing the employer’s income for a taxation year if:

  • it is paid in the fiscal year or within one hundred and twenty (120) days from the end of the fiscal year;
  • it was not deducted in the previous year; and
  • it is an eligible contribution under Subsection 147.2(2).
  • Subsection 147.2(2) of the Income Tax Act defines an eligible contribution as one which:
    • is made on the recommendation of an actuary;
    • is approved in writing by the Minister;
    • is based on an actuarial valuation prepared as of a date that is not more than four years before the day on which the contribution is made; and
    • is not in excess of prescribed limits if the plan is a designated plan.  A designated plan is one in which the total pension credit for members who either are connected with the employer or earn more than two and a half times the Year's Maximum Pensionable Earnings exceeds 50% of the total pension credit for all the members under the defined benefit provisions of the plan.  The prescribed limits are determined by using actuarial assumptions set forth in Section 8515(7) of the Income Tax Regulations.   
      Furthermore, the actuarial valuation must be:
      • based on an actuarial funding method that produces a reasonable matching of contributions with accruing benefits;
      • prepared based on generally-accepted actuarial principles; and
      • prepared based on assumptions that are reasonable both at the time the valuation is prepared and at the time the contribution is made.

If an excess actuarial surplus exists, the Company must apply this "excess" surplus against Company current service contribution requirements (Paragraph 147.2(2)(d)). Excess actuarial surplus is defined as the amount of actuarial surplus which is in excess of the lesser of 25% of the actuarial liability.


Deductibility - Timing of IPP Implementation

To ensure a contribution is deductible within a fiscal year for a new IPP, it is recommended that the plan be implemented (i.e., application submitted to Canada Revenue Agency) prior to the end of the fiscal year.  Despite the fact that a Company has 120 days after the fiscal year-end to make the contribution and have it deducted, an IPP should be implemented before the fiscal year-end to avoid a situation where Canada Revenue Agency denies the deduction by arguing that the IPP was not in effect within the fiscal year. Please note that there is a one-time implementation surcharge for late submissions to Westcoast Actuaries Inc. (less than 28 days before implementation deadline). 


Minimum Company Contributions

For provinces where the provincial pension legislation provides exemption for IPPs from registration and minimum funding requirements, there are no required minimum contributions by the Company. For IPPs that are subject to registration with the federal/provincial pension regulators, the minimum contributions by the Company each year are generally (please refer to the actual governing pension legislation for exact details on minimum funding) the sum of:

  • the Company's current service contribution for the year*; plus
  • the annual amortization payment required to liquidate the unfunded liability* (on a going-concern basis) over a period of 15 years; plus
  • the annual amortization payment required to liquidate the solvency deficiency* (on an assumed plan termination basis) over a period of 5 years.
    *    As identified in the latest actuarial valuation report.

    It is important to note that amortization payments are only required to the extent that they are deductible (see Maximum Company Contributions).

Certain plans are exempt from registration with the provincial pension regulator and are exempt from the minimum contribution requirements. Click here for further details.


Maximum Company Contributions

The maximum contribution is identified in our actuarial valuation report and is generally the total of:

  • Current service contributions to fund for benefits being earned in the current year.  Please note that Canada Revenue Agency requires that current service contributions for a connected person be made based on a percentage of the individual's T-4 earnings for the year; and
  • The unfunded liability (deficit), if any, under the plan.

If the actuarial valuation report identifies an excess actuarial surplus, the amount of excess actuarial surplus must be applied against Current Service Contributions (CSC) before any further tax-deductible contributions can be made to the plan.  Please refer to the two examples below:

 Example 1 Example 2  
 Year 1 Maximum CSC = $32,000  Year 1 Maximum CSC = $32,000
 Year 2 Maximum CSC = $34,400  Year 2 Maximum CSC = $34,400
 Year 3 Maximum CSC = $37,000  Year 3 Maximum CSC = $37,000
   
 (1) Amount of Actuarial Surplus = $72,000  (1) Amount of Actuarial Surplus = $135,000
 (2) Allowable Actuarial Surplus = $64,000  (2) Allowable Actuarial Surplus = $64,000
 (3) Excess Actuarial Surplus = $8,000 [ = (1) - (2) ]  (3) Excess Actuarial Surplus = $71,000 [ = (1) - (2) ]
   
 Maximum Allowable Contributions  Maximum Allowable Contributions
 Year 1 = $24,000 [ $32,000 CSC less $8,000* of excess ]  Year 1 = $0 [ $32,000 CSC less $32,000** of excess ]
 Year 2 = $34,400  Year 2 = $0 [ $34,400 CSC less $34,400** of excess ]
 Year 3 = $37,100  Year 3 = $32,400 [ $37,000 less $4,600** of excess ]
 *Total excess of $8,000  **Added up to a total excess of $71,000

 

Contribution In-Kind

Pension contributions do not necessarily have to be made in cash; they can be made in kind.  For example, investments can be transferred from the Company's corporate account to the pension account in the amount of the pension plan contribution.  This would potentially save the liquidation costs by the Company and the acquisition costs by the pension fund.  Attention should be paid to the following:

  • The contribution amount is based on the market value of the investments at the time of the transfer;
  • The investments being transferred or made in kind satisfy the investment rules for pension funds; and
  • The investments transferred from the company's corporate account to the pension account would be treated as a deemed disposition.
  • The company's accountant should be consulted to determine the effect of this deemed disposition (vis-à-vis capital gains or losses).
Content

【A】


Actuarially Equivalent - A benefit of equivalent actuarial present value when computed on the basis of interest, mortality and/or other rates and tables.


【B】



【C】


Canada Pension Plan (CPP) - A governmental pension plan that provides benefits to workers and their beneficiaries in Canada except Quebec in the event of retirement, disability or death.


CRA - Canada Revenue Agency - also known formerly as: Canada Customs and Revenue Agency; Canada Customs, Excise and Taxation; Revenue Canada, Taxation; and Department of National Revenue.


Commuted Value - A lump sum amount that is actuarially equivalent to a pension determined using certain actuarial bases. Most commuted values are determined in accordance with the Canadian Institute of Actuaries Revised Standards of Practice for Determining Commuted Values (CIA Commuted Value Standard), which came into effect April 1, 2011. Prior to April 1, 2011, commuted values were mostly calculated in accordance with the Canadian Institute of Actuaries Standard of Practice for Determining Commuted Values which came into effect on February 1, 2005.


Connected Person- A person who owns directly or indirectly 10% or more of any class of shares of a company or is not dealing at arm's length with such person.


Consumer Price Index (CPI) - A statistic that measures the change in the cost of living for consumers.  It is often used to measure inflation.


【D】


Defined Benefit (DB) - A pension design that defines the benefits payable at retirement.  The contribution amount is determined through actuarial valuation.  If a plan is registered for tax purposes, the maximum pension payable is defined by tax regulations.

Defined Benefit Limit (Defined Benefit Pension Plans) - The maximum amount of annual pension that can be paid from a defined benefit pension plan to a member for each year of pensionable service (or called credited service).  Based on current tax rules, the limit can be found on the CRA website. The limit is defined as the greater of $1,722.22 and 1/9 of the Money Purchase Limit.

2/3 Pensionable - Please note that for pre-1990 pensionable service recognized after June 7, 1990, the limit is only $1,150.00 (instead of $1,722.22) for years up to and including 2003 and 2/3 (two-thirds) of the Defined Benefit Limit for years after 2003.  These years of pre-1990 service are usually referred to as 2/3 pensionable.


Defined Contribution (DC) - A pension design that defines the amount of contributions, usually a percentage of salary.  The benefits payable at retirement depend on factors such as future investment return and annuity rate at retirement.  If a plan is registered for tax purposes, the maximum contribution amount (usually a percentage of earnings or income up to a dollar limit) is defined by tax regulations.


Defined Contribution Limit or Money Purchase Limit (Defined Contribution Pension Plans) - The maximum dollar amount of contribution that can be contributed to a defined contribution pension plan on behalf of a member.  Based on current tax rules, the aggregate contribution limit (the total of employer regular, employee regular and employee voluntary)  can be found on the CRA website. After 2016 the limit will increase at the rate of increase of the Average Industrial Wage Index for Canada.


Designated Plan - A Designated Plan is defined in Income Tax Regulation 8515(1) as a Registered Pension Plan that is primarily for the benefit of Connected Persons and Highly-Paid Employees.

【E】



【F】



Flexible Pension Plan - A defined benefit pension plan that allows plan members to earn Optional Ancillary Benefits by making Optional Ancillary Contributions.


【G】



【H】



Highly-Paid Employee - An employee who is paid at least 2.5 times the Year's Maximum Pensionable Earnings (YMPE) as defined by the Canada Pension Plan. The current YMPE can be found on the CRA website.

【I】



【J】


【K】



【L】


Life Income Fund (LIF) - A type of RRIF under which the owner must withdraw each year an amount that is between a minimum percentage prescribed by the Income Tax Act (Canada) and a maximum percentage prescribed by pension legislation (click here for applicable percentages for B.C.).


Locking-In - A condition imposed by pension legislation that requires funds either be used to provide a pension at retirement or be kept in a locked-in plan such as a Locked-In RRSP, LIRA, LRIF or LIF.


Locked-In Retirement Account (LIRA) - A type of RRSP where the funds are subject to locking-in under pension legislation. These funds must be used to purchase a life annuity, or be transferred to a LIF or an LRIF by the end of the year the owner attains age 71 at the latest. It is available in all jurisdictions except under the federal PBSA which provide for the locked-in RRSP that is very similar to the LIRA.


Locked-In Retirement Income Fund (LRIF) - A type of RRIF under which the owner must withdraw each year an amount that is between a minimum prescribed by the Income Tax Act (Canada) and a maximum amount prescribed by pension legislation. The LRIF is only available in Manitoba and in Newfoundland and Labrador.


Locked-In RRSP - A type of RRSP that is available under the federal PBSA to maintain funds that are locked-in as required by pension legislation. These funds must be used to purchase a life annuity or be transferred to a LIF by the end of the year the owner attains age 71 at the latest.


【M】


Maximum Transfer Limit - The maximum amount that can be transferred from a defined benefit pension plan to a money purchase provision (defined contribution pension plan, RRSP or RRIF) according to Income Tax Regulation 8517.  Please click here for details.


Money Purchase Limit - Refer to Defined Contribution Limit.


【N】


【O】



Office of the Superintendent of Financial Institutions (OSFI) - The entity that ensures pension plans governed by the Pension Benefits Standards Act, 1985 (PBSA) comply with the act and are administered in accordance with its requirements.


Old Age Security (OAS) - A monthly pension paid to Canadians over age 65 out of Government general revenue.


Optional Ancillary Benefits (OAB) - Benefits which are provided by Optional Ancillary Contributions under a Flexible Pension Plan.


Optional Ancillary Contributions (OAC) - Contributions made under a Flexible Pension Plan in order to acquire Optional Ancillary Benefits.


【P】


Past Service Pension Adjustment (PSPA) - Any pension benefits earned in a year after 1989 would reduce an individual's RRSP deduction limit for the following year through the reporting of a Pension Adjustment (PA).  If post-1989 past service benefits are provided or improved, it would trigger a provisional Past Service Pension Adjustment (PSPA) for the pension plan member which must be satisfied through one (or a combination) of the following means before such post-1989 past service benefits can be provided:

1.     Approval by CRA of Form T1004 (Applying For The Certification Of A Provisional PSPA) filed with them.  CRA will approve the form if the individual has sufficient unused RRSP room carried forward to satisfy the PSPA amount.  Please note that the individual's unused RRSP room would be reduced by the PSPA amount upon CRA's approval; or

2.     Transfer (tax-free) an amount from the pension plan member's RRSP or account in a Defined Contribution (DC) Pension Plan to the pension plan that provides the past service benefits.  Such transfer is commonly referred to as a Qualifying Transfer; or

3.     Withdraw an amount from the pension plan member's RRSP using CRA Form T1006 (Designating An RRSP Withdrawal As A Qualifying Withdrawal).

 
Pension Adjustment (PA) - Starting with 1990, a Pension Adjustment (PA) is reported on a pension plan member's T4.  The PA would reduce the member's RRSP deduction limit for the following year.  PA for a Defined Contribution (DC) pension plan member is the total employee and employer contributions made on the member's behalf as well as any forfeitures allocated to the member.  PA for a Defined Benefit (DB) pension plan member is calculated by a formula.  In simplified terms, it is equal to the annual pension amount earned by the member during the year first multiplied by 9 then subtracted by a prescribed amount ($1,000 for years before 1997 and $600 for 1997 and after).


Pension Adjustment Reversal (PAR) - The purpose of a PAR is to restore RRSP contribution room when an employee's membership in a provision of an RPP or DPSP stops and their termination benefit is less than the sum of PAs and PSPAs that have been reported to the Canada Revenue Agency (CRA). The PAR is reported to the CRA so that the employee's RRSP contribution room that was previously reduced by a PA or PSPA can be restored.
A PAR must be reported any time an individual stops being a member of a provision or plan after 1996. An individual does not have to terminate employment, only terminate plan membership.


Portability - The legislated right for an individual to transfer vested benefits to another registered retirement plan upon termination of employment or membership.


【Q】



Qualifying Transfer from RRSP - Transfer from a pension plan member’s personal RRSP to satisfy PSPA. For new plans, the Qualifying Transfer must be processed within 90 days of official registration by CRA.

Quebec Pension Plan (QPP) - A governmental pension plan similar to CPP that provides benefits to workers and their beneficiaries in Quebec in the event of retirement, disability or death.


【R】


Registered Disability Savings Plans (RDSP) - A registered disability savings plan is a trust arrangement between a holder and an issuer (a trust company in Canada). The purpose of such a plan is to provide for the long term financial security of a beneficiary who has a prolonged and severe physical or mental impairment and is entitled to the Disability Tax Credit. The RDSP is being administered jointly with Human Resources and Skills Development Canada (HRSDC).

Registered Pension Plans - A Registered Pension Plan (RPP) in Canada is a plan that is registered with Canada Revenue Agency for tax purposes under Section 147.1 of the Income Tax Act and if applicable the federal or provincial pension regulator.  The plan can be on a Defined Benefit (DB) or Defined Contribution (DC) basis.

Registered Plans - Plans such as Registered Pension Plans, Registered Retirement Savings Plans, Deferred Profit Sharing Plans, etc. that are registered for tax purposes.  Contributions to registered plans by the employer, employee or individual are deductible subject to limits.  Investment income earned by a registered plan is not taxed.  Benefits paid from a registered plan are taxable to the member or beneficiary when received.

Registered Retirement Income Fund (RRIF) - An arrangement under which the owner must withdraw each year a minimum amount prescribed by the Income Tax Act (Canada).  Funds usually originated from matured RRSPs or transfers from other registered plans.

Registered Retirement Savings Plan (RRSP) - A registered savings vehicle under Section 146 of the Income Tax Act arrangement into which an individual makes contributions for retirement savings purposes.

Related Person - Please see 
here for the full definition according to Section 251 of the Income Tax Act.

RRSP deduction limit -
The RRSP deduction limit for a year is the taxpayer’s unused RRSP deduction room at the end of the preceding taxation year, plus 18% of prior year earned income up to the RRSP maximum dollar limit for the current year less the Pension Adjustment (PA) for the prior year.

RRSP maximum dollar limit - The maximum dollar limit for RRSP can be found on the CRA website. Please note that these dollar limits are always one year behind the Money Purchase Limit to allow for reporting of Pension Adjustment (PA) on T4.

Retirement Compensation Arrangement (RCA) - An arrangement defined in subsection 248(1) of the Income Tax Act (Canada) under which an employer, former employer, or in some cases an employee, makes contributions to a custodian.  The custodian holds the funds in trust with the intent of eventually distributing them to the employee (beneficiary) on, after, or in view of retirement, other severance from employment, or any substantial change in the services the employee provides.

【S】

Spouse - See Provincial Pension Acts   – Definition of Spouse.   

【T】

Tax Free Savings Account (TFSA) - Starting in 2009, Canadian residents who are 18 years of age or older are able to earn tax free investment income within a TFSA during their lifetime. The maximum amount that can be contributed to a TFSA can be found on the CRA website. This amount will be indexed to inflation and rounded to the nearest $500 in subsequent years. Unused TFSA contribution room can be carried forward to later years. The total of TFSA withdrawals in a calendar year is added to the TFSA contribution room for the next calendar year. The CRA is responsible for monitoring and operating the TFSA, as applicable under the Act.


【U】




【V】



Vesting - This term refers to the acquisition of an unconditional right to pension benefits by a pension plan member after the completion of a certain period of employment or membership and sometimes the attainment of a certain age.  If a member is not vested at termination, he or she will be entitled to a refund of his or her own contributions, if any, with interest.


【W】




【X】




【Y】



Year's Maximum Pensionable Earnings (YMPE) - The amount of earnings each year as defined for purposes of determining the maximum amount of contributions payable to and the maximum amount of benefits payable from the CPP/QPP.  The amount increases annually at the rate of average wage growth in Canada.


【Z】