2 November 2009 External T.I. 2009-0308741E5 F - Fonds de formation -- summary under Paragraph (d)

The collective agreement between the Corporation and the Union provided for the establishment and funding by the Corporation of a training fund for the employees, which financed the training of laid-off workers, e.g., in courses leading to a vocational studies or college diploma, and also provided them with income while in school. In finding that the fund was an employee benefit plan ("EBP"), CRA referred to the exclusion in para. (d), and stated that it did not apply “since the training received by the laid-off workers does not necessarily relate to their skills respecting their duties with the Corporation” and “Rather, it appears that the funded training was intended to enable employees to find work in a field other than that of the Corporation.”