Before an Irish resident became a Canadian resident, she transferred the funds from a conventional Irish company pension plan to an Irish Personal Retirement Savings Account (PRSA), and will then transfer the funds in the PRSA to an Irish Approved Retirement Fund (ARF). In finding that neither the PRSA nor the ARF qualified as a pension plan or an employee benefits plan, CRA stated:
If no employer contributions have been made to a foreign retirement plan, the plan will not be considered a pension plan, nor an EBP. In accordance with Abrahamson … the fact that the original source of funds in a foreign individual retirement plan was a pension plan is not relevant.
On this basis:
withdrawals from the plan would not be required to be included in the recipient’s income under paragraph 56(1)(a) of the Act as pension income nor under paragraph 6(1)(g) as an amount received out of an EBP. Nevertheless, any income or capital gain earned in connection with such a plan is generally taxable in Canada on a current, annual basis … .