| Supply and Services Canada | |
| Accounting, Banking and | |
| Compensation Directorate | File No. 900880 |
| Place du Portage | Maureen Shea-DesRosierss |
| 11A1, Phase III | (613) 957-8953 |
| Ottawa, Ontario | |
| K1A 0S5 | |
| Attention: Jan MorrisAdvisory Services - PayPay Products Group Compensation |
June 5, 1990
Dear Sirs:
Re: Past service contributions "While a contributor" or "While not a contributor"
This is in reply to your letter of May 18, 1990 concerning the tax deductibility of registered pension plan contributions.
To be able to indicate whether the contributions were in respect of a period "while a contributor" or "while not a contributor", the contract of employment is needed to verify the length of time the individual is hired (ex. 6 months, 8 months).
Paragraph 5(1)(b) of the Public Service Superannuation Act states that a person employed in the Public Service for a term of six months or less is not required to contribute to the Superannuation Plan unless such person has been employed substantially without interruption for a period of more than 6 months.
Therefore a person employed for less than six months, usually referred to as a casual employee, does not contribute to the Superannuation Plan and such service will, in our opinion, be considered a period while the person was "not a contributor".
A person hired for a period of more than 6 months, usually referred to as a term employee, will have to contribute to the Superannuation Plan from one day and the total employment period will be considered a period "while a contributor".
Should a person be employed for a period of 6 months (as a casual employee) and then have the contract renewed for another 6 months, the person would then contribute to the Superannuation Plan starting with the second 6 month period and that period will be considered to be a period "while a contributor" while the first 6 month period will be a period "while not a contributor".
Since we had no information pertaining to the contracts of employment, we were unable to answer your three scenarios as presented. We trust however that our comments will enable you to apply the "while or while not a contributor" concept to any of the situations that might present themselves to you.
Yours truly,
for DirectorFinancial Industries DivisionRulings Directorate