Business
What is a Retirement Compensation Arrangement (“RCA”)?
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].
Business
The great policy challenge for governments in Canada in 2026
From the Fraser Institute
According to a recent study, living standards in Canada have declined over the past five years. And the country’s economic growth has been “ugly.” Crucially, all 10 provinces are experiencing this economic stagnation—there are no exceptions to Canada’s “ugly” growth record. In 2026, reversing this trend should be the top priority for the Carney government and provincial governments across the country.
Indeed, demographic and economic data across the country tell a remarkably similar story over the past five years. While there has been some overall economic growth in almost every province, in many cases provincial populations, fuelled by record-high levels of immigration, have grown almost as quickly. Although the total amount of economic production and income has increased from coast to coast, there are more people to divide that income between. Therefore, after we account for inflation and population growth, the data show Canadians are not better off than they were before.
Let’s dive into the numbers (adjusted for inflation) for each province. In British Columbia, the economy has grown by 13.7 per cent over the past five years but the population has grown by 11.0 per cent, which means the vast majority of the increase in the size of the economy is likely due to population growth—not improvements in productivity or living standards. In fact, per-person GDP, a key indicator of living standards, averaged only 0.5 per cent per year over the last five years, which is a miserable result by historic standards.
A similar story holds in other provinces. Prince Edward Island, Nova Scotia, Quebec and Saskatchewan all experienced some economic growth over the past five years but their populations grew at almost exactly the same rate. As a result, living standards have barely budged. In the remaining provinces (Newfoundland and Labrador, New Brunswick, Ontario, Manitoba and Alberta), population growth has outstripped economic growth, which means that even though the economy grew, living standards actually declined.
This coast-to-coast stagnation of living standards is unique in Canadian history. Historically, there’s usually variation in economic performance across the country—when one region struggles, better performance elsewhere helps drive national economic growth. For example, in the early 2010s while the Ontario and Quebec economies recovered slowly from the 2008/09 recession, Alberta and other resource-rich provinces experienced much stronger growth. Over the past five years, however, there has not been a “good news” story anywhere in the country when it comes to per-person economic growth and living standards.
In reality, Canada’s recent record-high levels of immigration and population growth have helped mask the country’s economic weakness. With more people to buy and sell goods and services, the overall economy is growing but living standards have barely budged. To craft policies to help raise living standards for Canadian families, policymakers in Ottawa and every provincial capital should remove regulatory barriers, reduce taxes and responsibly manage government finances. This is the great policy challenge for governments across the country in 2026 and beyond.
Business
How convenient: Minnesota day care reports break-in, records gone
A Minneapolis day care run by Somali immigrants is claiming that a mysterious break-in wiped out its most sensitive records, even as police say officers were never told that anything was actually stolen — a discrepancy that’s drawing sharp attention amid Minnesota’s spiraling child care fraud scandal.
According to the center’s manager, Nasrulah Mohamed, someone forced their way into Nakomis Day Care Center earlier this week by entering through a rear kitchen area, damaging a wall and accessing the office. Mohamed told reporters the intruder made off with “important documentation,” including children’s enrollment records, employee files, and checkbooks tied to the facility’s operations.
But a preliminary report from the Minneapolis Police Department tells a different story. Police say no loss was reported to officers at the time of the call. While the department confirmed the center later contacted police with additional information, an updated report was not immediately available.
Video released by the day care purporting to show damage from the incident depicts a hole punched through drywall inside what appears to be a utility closet, with stacks of cinder blocks visible just behind the wall — imagery that has only fueled skepticism as investigators continue to unravel what authorities have described as one of the largest fraud schemes ever tied to Minnesota’s human services programs.
Mohamed blamed the alleged break-in on fallout from a viral investigation by YouTuber Nick Shirley, who recently toured nearly a dozen Minnesota day care sites while questioning whether they were legitimately operating. Shirley’s video has racked up more than 110 million views. Mohamed insisted the coverage unfairly targeted Somali operators and said his center has since received what he described as hateful and threatening messages.
A manager at the Nokomis Daycare Center in Minneapolis detailed "extensive vandalism" at the facility during a Wednesday news conference.
Manager Nasrulah Mohamed reported that the suspect stole important employee and client documents, an incident he attributed to YouTuber Nick… pic.twitter.com/71nNTSXdTT
— FOX 9 (@FOX9) December 31, 2025
“This is devastating news, and we don’t know why this is targeting our Somali community,” Mohamed said, calling Shirley’s reporting false. Nakomis Day Care Center was not among the facilities featured in the video.
The break-in claim surfaced as law enforcement and federal officials continue to expose a massive fraud network centered in Minneapolis, involving food assistance, housing, and child care payments. Authorities say at least $1 billion has already been identified as fraudulent, with federal prosecutors warning the total could climb as high as $9 billion. Ninety-two people have been charged so far, 80 of them Somali immigrants.
Late Tuesday, the U.S. Department of Health and Human Services announced it was freezing all federal child care payments to Minnesota unless the state can prove the funds are being used lawfully. The payments totaled roughly $185 million in 2025 alone.
Minnesota Gov. Tim Walz, under intensifying scrutiny for allowing fraud to metastasize for years, responded by attacking the Trump administration rather than addressing the substance of the findings. “This is Trump’s long game,” Walz wrote on X Tuesday night, claiming the administration was politicizing fraud enforcement to defund programs — despite federal officials pointing to documented abuse and ongoing criminal cases.
Meanwhile, questions continue to swirl around facilities already flagged by investigators. Reporters visiting several sites highlighted in Shirley’s video found at least one — Quality “Learing” Center — operating with children inside despite state officials previously saying it had been shut down. The Minnesota Department of Children, Youth, and Families later issued a confusing clarification, saying the center initially reported it would close but later claimed it would remain open.
As Minnesota scrambles to respond to the funding freeze and mounting arrests, the conflicting accounts surrounding the Nakomis Day Care incident underscore a broader problem confronting state leaders: a system so riddled with gaps and contradictions that even basic facts — like whether records were actually stolen — are now in dispute, while taxpayers are left holding the bill.
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