4 June 2020 External T.I. 2018-0753611E5 - Form T1135 and US pension plan -- summary under Paragraph (n)

There was no adverse impact on the exclusion in para. (n) for a Canadian beneficiary where, following an asset insufficiency in a US qualified pension plan, the Pension Benefit Guaranty Corporation, as replacement trustee, commenced paying the plan benefits to the members (the majority of whom resided in the US).