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What is a Retirement Compensation Arrangement (“RCA”)?

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An RCA is a plan that is funded by contributions from employers and employees to a custodian who manages the funds. RCAs are used to fund the retirement of an employee, their loss of employment or a substantial change in the services that they provide.

How it works?

Employers make annual tax deductible contributions to an RCA that are subject to a refundable 50% withholding tax. Since the payments are not made to the employee, they are not subject to any tax implications in the year the contributions are made.  When payments are made from the plan to the employee, the refundable taxes paid are recovered at the same rate (e.g. $1 of every $2 paid). All income earned within the plan is subject to the refundable 50% tax and is recoverable at the same rate as above. The employee pays personal tax on distributions from the RCA in the year they are received.

Employees can also make tax deductible contributions to an RCA. The contributions are similarly considered deductible and subject to the 50% refundable withholding tax.

Types of plans

An RCA can be set up as either a Defined Benefit Plan (“DBP”) or a Defined Contribution Plan (“DCP”). As the title suggests, a DBP provides employees with a defined pension amount annually, upon retirement. Whereas employees on a DCP will receive only what was contributed to the plan, plus any income earned or less any losses incurred, a DBP will require the periodic involvement of an actuary to determine whether the plan is properly funded.

A DBP puts the risk of losses on investments in the hands of the employer and a DCP passes that risk to the employees as they will receive what is remaining in the plan.

Who will benefit from RCAs?

Employees

Employees who participate in an RCA will enjoy future pension benefits and peace of mind knowing that, if the employer were to close down and they lost their employment, the assets of the RCA would be protected against the creditors of the employer.

The 50% refundable withholding rate is currently less than the top tax bracket in a number of provinces. As such, the after-tax investment for the pension is no longer considered a disadvantage to RCAs for high-income earning employees as the plan will invest 50% of the amount they are paid as opposed to less than 50%, had they been paid as a salary.

Contributions to the RCA by an employer will not reduce the RRSP contribution room for the employee, which is not the case for contributions made to a Retirement Pension Plan (“RPP”).

Further tax savings can be obtained by paying the employees out of the RCA in future years when their income levels are lower and subject to lower marginal tax rates.  When you consider the ability to include income in lower income earning years, employees living in provinces and territories not subject to >50% tax at the top rate can still benefit from an RCA.

Employers

Employers may wish to provide a retirement package for their employees but not pay the high costs of operating an RPP or an Individual Pension Plan (“IPP”). If the owner-manager of the company or someone already within the company completes the required remittance forms and bookkeeping for the plan, the costs associated with an RCA would include the preparation of the trust return, identified above, and investment advisor fees, if an advisor is used. Additional costs may be applicable for DPBs since possible periodic actuarial valuations may be needed to ensure the plan is properly funded.

Employers can also utilize RCAs for what’s referred to as “Golden Handcuffs,” meaning they can require an employee to meet certain length-of-employment requirements before the pension contributions vest. This will help employers retain key employees that are vital to their operations.

Tax benefits for employer

One group that may benefit most from these plans are companies involved in Scientific Research and Experimental Development (“SRED”) that must maintain low taxable income and taxable capital figures to retain their benefits from the enhanced investment tax credits. Since the taxable income and taxable capital figures exceed $500,000 and $10,000,000, respectively, the amount eligible for the enhanced tax credit decreases.

Federally, expenditures eligible for the enhanced tax credit are eligible for a 35% tax credit, whereas expenditures not eligible only provide for a 15% tax credit. When you also consider the provincial tax credit implications, it’s critical for these companies to maintain sufficient expenditure pool levels.

One common method for ensuring low income and taxable capital figures is to declare bonuses for the owner-managers and to pay those bonuses out of the company to reduce taxable capital. This is a good opportunity to use RCAs. The top tax rate in seven of Canada’s thirteen provinces or territories is over 50%. Given the RCA withholding rates are currently 50%, this can provide a deferral of up to 4% depending on your province. When you add the additional payroll costs, this can result in significant savings.

How much should be contributed?

An employer must be careful not to contribute an unreasonable amount to the plan on behalf of an employee as it could result in the plan being re-characterized as an SDA.  The starting point for a reasonable DCP amount would be the 18% that is used to create RRSP deduction room annually. A higher rate would likely require a very strong argument as to why it’s reasonable.

A DBP requires a certain level of assets to be held within the plan to support the future pension obligations that an actuary has calculated. Given that the plan will require a certain amount, a reasonable contribution will be the amount that brings the assets of that plan to a sufficient level to fund that obligation. The pension benefit, however, must be considered a reasonable amount.  Again, a reasonable amount will vary based on the facts of each situation.

The CRA has indicated that it will permit a deduction for recognition of an employee’s years of services even if it occurred prior to the establishment of the RCA.1 Since past years of service can be recognized, large contributions may be eligible when the RCA is initially established.

Careful planning is required to ensure that the plan meets the criteria of an RCA as adverse tax effects could result otherwise.  You should seek professional advice if you are setting up an RCA.

Jesse Genereaux is a tax manager in the Durham office of Collins Barrow.

Want to get in touch with Jesse?
Connect with him by email at [email protected].

Agriculture

Liberal win puts Canada’s farmers and food supply at risk

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This article supplied by Troy Media.

By Sylvain Charlebois 

A fourth Liberal term means higher carbon taxes and trade risks. Could Canada’s farmers and food security be on the line?

The Liberal Party, now led by Mark Carney, has secured a fourth consecutive term, albeit once again with a minority mandate. This time, however, the Liberals have a stronger hand, as they can rely not only on the NDP but also the Bloc Québécois to maintain power.

This broader base of parliamentary support could provide much-needed political stability at a crucial time, particularly as Canada prepares for a new round of trade negotiations with the United States and Mexico.

For the agri-food sector, the implications are significant. From carbon taxes to trade rules, federal decisions play a decisive role in shaping the costs and risks Canadian farmers face.

First and foremost, carbon pricing will remain a central issue. Carney has made it clear that the industrial carbon tax will stay—a policy that continues to erode the competitiveness of Canada’s agri-food sector, where fuel, fertilizer and transportation costs are especially sensitive to carbon pricing. The tax, currently set at $95 per metric tonne, is scheduled to climb to $170 by 2030.

While consumers may not see this tax directly, businesses certainly do. More concerning is the Liberals’ intention to introduce a border carbon adjustment for imports from countries without equivalent carbon pricing regimes. While this could theoretically protect Canadian industry, it also risks making food even more expensive for Canadian consumers, particularly if the U.S., our largest trading partner, remains uninterested in adopting similar carbon measures. Acting alone risks undermining both our food security and our global competitiveness.

Another looming issue is supply management. Although all parties pledged during the campaign not to alter Canada’s system for dairy, poultry and eggs, this framework—built on quotas and high import tariffs—is increasingly outdated. It is almost certain to come under pressure during trade negotiations. The American dairy lobby, in particular, will continue to demand greater access to Canadian markets. The Liberals have a chance to chart a more forward-looking path. Modernizing supply management could lead to a more competitive, resilient industry while providing consumers with greater choice and better prices.

The previous Parliament’s passage of Bill C-282, which sought to shield supply managed sectors from all future trade negotiations, was a deeply flawed move.

Fortunately, the new parliamentary makeup should make it far less likely that such protectionist legislation will survive. A more pragmatic approach to trade policy appears possible.

On the domestic front, there are reasons for cautious optimism. The Liberals have promised to eliminate remaining federal barriers to interprovincial trade and to improve labour mobility, longstanding obstacles to the efficient movement of agri-food products across Canada. For example, differing provincial rules often prevent products like cheese, meat or wine from being sold freely across provinces, frustrating farmers and limiting consumer choice. Momentum was building before the election, and it must continue if we are serious about building a stronger domestic food economy.

Infrastructure investment is another bright spot. The Liberals pledged more than $5 billion through a Trade Diversification Corridor Fund to upgrade Canada’s severely undercapitalized export infrastructure. Strategic investment in trade gateways is overdue and critical for agri-food exporters looking to reduce reliance on the United States and expand into global markets.

Finally, the Liberal platform was alone in explicitly committing to support food processing in Canada, a crucial pillar of domestic food security. An increased focus on manufacturing will not only create jobs but also reduce reliance on imported food products, making Canada more resilient in the face of global disruptions.

Farmers have long felt sidelined by urban-centric Liberal governments. The past four years were marked by regulatory and trade clashes that deepened that divide. The hope now is that with greater political stability and a clearer focus on  competitiveness, the next four years will bring a more constructive relationship between Ottawa and Canada’s agri-food sector.

If the Liberals are serious about food security and economic growth, now is the time to reset the relationship with Canada’s farmers, not ignore them yet again.

Dr. Sylvain Charlebois is a Canadian professor and researcher in food distribution and policy. He is senior director of the Agri-Food Analytics Lab at Dalhousie University and co-host of The Food Professor Podcast. He is frequently cited in the media for his insights on food prices, agricultural trends, and the global food supply chain.

Troy Media empowers Canadian community news outlets by providing independent, insightful analysis and commentary. Our mission is to support local media in helping Canadians stay informed and engaged by delivering reliable content that strengthens community connections and deepens understanding across the country.

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Trump’s bizarre 51st state comments and implied support for Carney were simply a ploy to blow up trilateral trade pact

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From LifeSiteNews

By Conservative Treehouse

Trump’s position on the Canadian election outcome had nothing to do with geopolitical friendships and everything to do with America First economics.

Note from LifeSiteNews co-founder Steve Jalsevac: This article, disturbing as it is, appears to explain Trump’s bizarre threats to Canada and irrational support for Carney. We present it as a possible explanation for why Trump’s interference in the Canadian election seems to have played a large role in the Liberals’ exploitation of the Trump threat and their ultimate, unexpected success.

To understand President Trump’s position on Canada, you have to go back to the 2016 election and President Trump’s position on the North American Free Trade Agreement (NAFTA) renegotiation. If you did not follow the subsequent USMCA process, this might be the ah-ha moment you need to understand Trump’s strategy.

During the 2016 election President Trump repeatedly said he wanted to renegotiate NAFTA. Both Canada and Mexico were reluctant to open the trade agreement to revision, but ultimately President Trump had the authority and support from an election victory to do exactly that.

In order to understand the issue, you must remember President Trump, Commerce Secretary Wilbur Ross, and U.S. Trade Representative Robert Lighthizer each agreed that NAFTA was fraught with problems and was best addressed by scrapping it and creating two separate bilateral trade agreements. One between the U.S. and Mexico, and one between the U.S. and Canada.

In the decades that preceded the 2017 push to redo the trade pact, Canada had restructured their economy to: (1) align with progressive climate change; and (2) take advantage of the NAFTA loophole. The Canadian government did not want to reengage in a new trade agreement.

Canada has deindustrialized much of their manufacturing base to support the “environmental” aspirations of their progressive politicians. Instead, Canada became an importer of component goods where companies then assembled those imports into finished products to enter the U.S. market without tariffs. Working with Chinese manufacturing companies, Canada exploited the NAFTA loophole.

Justin Trudeau was strongly against renegotiating NAFTA, and stated he and Chrystia Freeland would not support reopening the trade agreement. President Trump didn’t care about the position of Canada and was going forward. Trudeau said he would not support it. Trump focused on the first bilateral trade agreement with Mexico.

When the U.S. and Mexico had agreed to terms of the new trade deal and 80 percent of the agreement was finished, representatives from the U.S. Chamber of Commerce informed Trudeau that his position was weak and if the U.S. and Mexico inked their deal, Canada would be shut out.

When they went to talk to the Canadians the CoC was warning them about what was likely to happen. NAFTA would end, the U.S. and Mexico would have a bilateral free trade agreement (FTA), and then Trump was likely to turn to Trudeau and say NAFTA is dead, now we need to negotiate a separate deal for U.S.-Canada.

Trudeau was told a direct bilateral trade agreement between the U.S. and Canada was the worst possible scenario for the Canadian government. Canada would lose access to the NAFTA loophole and Canada’s entire economy was no longer in a position to negotiate against the size of the U.S. Trump would win every demand.

Following the warning, Trudeau went to visit Nancy Pelosi to find out if Congress was likely to ratify a new bilateral trade agreement between the U.S. and Mexico. Pelosi warned Trudeau there was enough political support for the NAFTA elimination from both parties. Yes, the bilateral trade agreement was likely to find support.

Realizing what was about to happen, Prime Minister Trudeau and Chrystia Freeland quickly changed approach and began to request discussions and meetings with USTR Robert Lighthizer. Keep in mind more than 80 to 90 percent of the agreement was already done by the U.S. and Mexico teams. Both President Andres Manuel Lopez Obrador and President Trump were now openly talking about when it would be finalized and signed.

Nancy Pelosi stepped in to help Canada get back into the agreement by leveraging her Democrats. Trump agreed to let Canada engage, and Lighthizer agreed to hold discussions with Chrystia Freeland on a tri-lateral trade agreement that ultimately became the USMCA.

The key points to remember are: (1) Trump, Ross, and Lighthizer would prefer two separate bilateral trade agreements because the U.S. import/export dynamic was entirely different between Mexico and Canada. And because of the loophole issue, (2) a five-year review was put into the finished USMCA trade agreement. The USMCA was signed on November 30, 2018, and came into effect on July 1, 2020.

TIMELINE: The USMCA is now up for review (2025) and renegotiation in 2026!

This timeline is the key to understanding where President Donald Trump stands today. The review and renegotiation is his goal.

President Trump said openly he was going to renegotiate the USMCA, leveraging border security (Mexico) and reciprocity (Canada) within it.

Following the 2024 presidential election, Prime Minister Justin Trudeau traveled to Mar-a-Lago and said if President Trump was to make the Canadian government face reciprocal tariffs, open the USMCA trade agreements to force reciprocity, and/or balance economic relations on non-tariff issues, then Canada would collapse upon itself economically and cease to exist.

In essence, Canada cannot survive as a free and independent north American nation, without receiving all the one-way benefits from the U.S. economy.

To wit, President Trump then said that if Canada cannot survive in a balanced rules environment, including putting together their own military and defenses (which it cannot), then Canada should become the 51st U.S. state. It was following this meeting that President Trump started emphasizing this point and shocking everyone in the process.

However, what everyone missed was the strategy Trump began outlining when contrast against the USMCA review and renegotiation window.

Again, Trump doesn’t like the tri-lateral trade agreement. President Trump would rather have two separate bilateral agreements; one for Mexico and one for Canada. Multilateral trade agreements are difficult to manage and police.

How was President Trump going to get Canada to (a) willingly exit the USMCA; and (b) enter a bilateral trade agreement?

The answer was through trade and tariff provocations, while simultaneously hitting Canada with the shock and awe aspect of the 51st state.

The Canadian government and the Canadian people fell for it hook, line, and sinker.

Trump’s position on the Canadian election outcome had nothing to do with geopolitical friendships and everything to do with America First economics. When asked about the election in Canada, President Trump said, “I don’t care. I think it’s easier to deal, actually, with a liberal and maybe they’re going to win, but I don’t really care.”

By voting emotionally, the Canadian electorate have fallen into President Trump’s USMCA exit trap. Prime Minister Mark Carney will make the exit much easier. Carney now becomes the target of increased punitive coercion until such a time as the USMCA review is begun, and Canada is forced to a position of renegotiation.

Trump never wanted Canada as a 51st state.

Trump always wanted a U.S.-Canada bilateral trade agreement.

Mark Carney said the era of U.S.-Canadian economic ties “are officially declared severed.”

Canada has willingly exited the USMCA trade agreement at the perfect time for President Trump.

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