29 March 1994 Administrative Letter 9317296 F - 6359 Foreign Tax Credit - Social Security Contributions -- summary under Non-Business-Income Tax

Mandatory contributions made to a foreign social security plan, which is similar to the U.S. one, for example, to the German social security plan, will constitute an "income or profits" tax for purposes of s. 126(1) and s. 115(2)(e)(i)(A). However, voluntary contributions to the social security plans of countries other than Canada will not be considered to be income or profits taxes.