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What’s New in Pension and Benefits – Fall 2025

September 26, 2025 | Evan Shapiro, WTW, and Patrick Simon, OPB

LEGISLATION

DRAFT ITA AND ITR AMENDMENTS

The federal government has released draft amendments to the Income Tax Act (ITA) and Income Tax Regulations (along with Explanatory Notes). Comments were requested by September 12, 2025. Effective for tax years ending from and including December 31, 2025, retirement compensation arrangements (RCAs) that supplement registered pension plans will be exempt from the enhanced trust reporting requirements notably the extensive beneficiary disclosure in Schedule 15 to the T3 return, which were introduced in 2023. The CBA advocated successfully for this amendment in a July 2024 submission to the Department of Finance Canada. Other proposed amendments relate to:

  • Unclaimed property transfers
  • Contributions (non-participating employers; transfer ratios under 1.0)
  • Information when determining periods of disability
  • Funding additional benefits because of a past service event
  • Individual Pension Plans
  • Securities lending arrangements
  • Technical amendments relating to various types of annuities
  • Technical amendments relating to various registered vehicles
  • Treatment of US 401(k) plans

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