pension

A French citizen residing in Canada had helped to run the family farm in France and, to thank him for those seven years of contribution, his father paid him a lump sum as “deferred salary”, a concept introduced by the French legislature pursuant to a Decree for the purpose of equity, namely to compensate a person who had contributed without consideration to the enrichment of the family group and to redu

Regarding the receipt by an individual resident in Italy of periodic Canada Pension Plan (“CPP”) and Old Age Security (“OAS”) benefit payments, the Directorate found that

The holder in France of an "assurance-salaire-vie," which is similar to a registered retirement savings plan except that a withdrawal from it is taxable only if made within the first eight years of the contribution, immigrates to Canada. The Directorate indicated that it was unlikely that withdrawals from the plan would be exempted under Art. XVIII(1) of the France-Canada Convention as a “pension” as the only contributions were employee contributions, nor would they qualify as an :annuity” per Art.