A Canadian resident, who had lived in Switzerland for a number of years before returning, now holds a pension account in Switzerland known as a "Vested Benefits Account" (exceeding $100,000) that is a pension mechanism provided for under Swiss law from which retirement benefits will be paid when the individual has reached the required age and meets the other conditions set out in the Swiss Federal Law on the Occupational Old-Age, Survivors' and Disability Benefit Plans (LOB). Before indicating that this asset was not excluded under s. 233.3(1) – specified foreign property – para. (n) as an interest in an exempt trust and, thus, was subject to the s. 233.3 reporting requirement, CRA noted that the para. (n) exception referenced:
an interest in various classes of trusts, including trusts that provide for certain annuity or pension payments. Several strict conditions must be satisfied in order for such trusts to be considered excluded foreign property.