2019 Ruling 2019-0803761R3 - New RCA to replace benefits under existing RCA -- summary under Subsection 207.6(7)

CRA ruled that a new supplemental pension plan would qualify as a retirement compensation arrangement and that s. 207.6(7) would apply to the transfer from the old RCA trust to the new one (which would also entail CRA being asked to now hold the existing 50% refundable tax for the account of the new trust). The new trust had similar terms to, but with more flexible payout terms than, the old trust.