An individual who participated in a defined benefit pension plan established in Europe by the U.S. employer for its expatriate employees immigrated to, and became a resident of, Canada following retirement. The employer has decided to wind up the pension plan by using funds in the plan to purchase annuity contracts for each retired member.
After noting that where the conditions under s. 147.4(1) are satisfied, “the individual is deemed not to have received an amount from the RPP as a result of acquiring the annuity and any amounts received under the contract are deemed to be amounts received under the RPP,” so that “there is no immediate taxation on the acquisition of the annuity,” CRA stated:
However, there is no comparable provision in the Act for annuities purchased from foreign pension plans.
… [T]he individual will be considered to have received a pension benefit equal to the fair market value of the annuity contract at the time the individual acquires it and must include this amount in their income under subparagraph 56(1)(a)(i).