Regarding whether it would be permitted for an additional premium to subsequently be paid under the terms of the annuity contract for new employees who subsequently become annuitants under that contract, CRA stated:
To be an annuity contract within the meaning of subsection 147.4(1), it is our view that the contract can only allow for one premium at the time of acquisition or thereafter. Thus, any additional premiums that the employer would like to pay after the annuity contract is issued would have to be the subject of a new contract.