Regarding whether a profit sharing plan can be registered as a DPSP when the corporation has an accumulated deficit, CRA indicated, yes, s. 147 does not require the corporation to have retained earnings to be approved as a profit-sharing plans, and went on to state:
[T]he amounts to be paid by the employer are normally computed by reference to profits (e.g. 5% of the profits) as defined in the plan. They may be computed in another way, provided that the amounts come from profits.