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10 March 2004 External T.I. 2002-0160751E5 F - REÉR au décès: rente pour un bénéficiaire mineur -- summary under Clause 60(l)(ii)(B)

The annuitant of a registered retirement savings plan ("RRSP") died, leaving his RRSP in trust for his minor child. The executor of the estate will acquire an annuity equal in value to the value of the RRSP, with a term equal to 18 years minus the age of the minor child, with the estate (a trust) as the annuitant. Under the terms of the will, the trustee could use all or part of the income or capital of the trust for the child's needs at the trustee’s sole discretion, with the capital distributed to the child at specified times.

12 June 2009 Internal T.I. 2008-0294921I7 F - Montant reçu à l'égard d'un surplus actuariel -- summary under Superannuation or Pension Benefit

On the sale by the Vendor of one of its business divisions, the employees of that division were transferred to the purchaser, and the assets of the defined benefit pension plan regarding those employees (the “Plan”) were transferred to the Purchaser and the Purchaser assumed the related pension commitments, in two transfers (which was permitted as a result of the approval of the Régie des rentes du Québec).

By services, 28 November, 2015

Dominion of Canada General Insurance Co. v. The Queen, 86 DTC 6154, [1986] 1 CTC 423 (FCA) -- summary under Paragraph 12(1)(e)

Stone JA stated (at p. 6163) that the words of s. 85B(1)(e) (now, s. 12(1)(e)) "are directed toward the inclusion in income of an 'amount' that was 'deducted' in the previous year and not toward an amount that was 'deductible' in that year." Where an amount was in fact deducted in a previous year by a taxpayer purporting to comply with the provisions of what now is s. 20(1)(m), that amount was to be brought into income under s. 12(1)(e) notwithstanding that the deduction in the previous year may not have been properly taken.

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