Principal Issues: What is the status of the CRA's review of RCA Trusts
Position: The review is ongoing
QUESTION #18 - RCA TRUSTS
We understand that the CRA has started to review RCA Trusts. Can you let us know the status of the review?
CRA Response
The number of RCAs registered in recent years has increased significantly. The refundable tax creates an enormous liability for the government that must be managed. Reviews of these trust arrangements are identifying issues that are of concern to the CRA, including whether a bona fide RCA even exists (versus a salary deferral arrangement for example). The CRA will continue to audit RCAs and any positions taken will be based on the facts of each case.
Phil Kohnen
June 2-3, 2011
2011-040194