Appeal from Canada Revenue Agency’s decision to issue notice of intent to revoke registration of newly created pension plan
(President’s Plan or Plan) of which Mrs. Greenhalgh sole member by virtue of position as President of appellant corporation,
pursuant to Income Tax Act, R.S.C., 1985 (5th Supp.), c. 1, s. 147.1(11)(a)—Commuted value of Mrs. Greenhalgh’s pension
with Ontario Teachers’ Pension Plan transferred to President’s Plan—Notice of intent issued on basis Plan not satisfying
condition in Income Tax Regulations (ITR), C.R.C., c. 945, s. 8502(a) that primary purpose to provide lifetime retirement
benefits to employees in respect of service as employees—Appellant not demonstrating Minister’s reasons for determination ITR
condition not met unsound, unsupported by record—Appeal dismissed.
1346687 ONTARIO INC. V. M.N.R. (A-471-05, 2007 FCA 262, Ryer J.A., judgment dated 27/7/07, 23 pp.)