A Canadian professional sports team has established an RCA for the benefit of an athlete employee under which the athlete and the team are each required to each annually contribute $400,000 to the RCA, would the athlete be entitled to a deduction under s. 8(1)(m.2) for his contributions to the RCA? In finding that no such deduction was permitted, CRA stated:
Generally, a plan will be considered to be a pension plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payment on or after the employee's retirement.
… [A] plan will not be a pension plan where the only payment provided for under the terms of the plan is a single lump sum payable on retirement or loss of employment. … [A] plan that is excluded from being a salary deferral arrangement (“SDA”) by virtue of the special exception for professional athletes in paragraph (j) of the SDA definition in subsection 248(1) [also] will not be a pension plan, regardless of the form of benefits provided.