12 August 2010 External T.I. 2010-0360171E5 F - Déclaration T-1135 et biens étrangers -- summary under Paragraph (n)

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). Without providing detailed analysis, CRA indicated 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.