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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].

Business

Inflation Reduction Act, Green New Deal Causing America’s Energy Crisis

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From the Daily Caller News Foundation

By Greg Blackie

Our country is facing an energy crisis. No, not because of new demand from data centers or AI. Instead, it’s because utilities in nearly every state, due to government imposed “renewable” mandates, self-imposed mandates, and the supercharging of the Green New Scam under the so-called “Inflation Reduction Act,” have been shutting down vital coal resources and building out almost exclusively intermittent and costly resources like solar, wind, and battery storage.

President Donald Trump understands this, and that is why on day one of his administration he declared an Energy Emergency. Then, a few months later, the President signed a trio of Executive Orders designed to keep our “beautiful, clean coal” burning and providing the reliable, baseload, and affordable electricity Americans have benefitted from for generations.

Those orders have been used to keep coal generation online that was slated to shut down in Michigan and will potentially keep two units operating that were scheduled to shut down in Colorado this December. In Arizona, however, the Cholla Power Plant in Navajo County was shuttered by the utility just weeks after Trump explicitly called out the plant for saving in a press conference.

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Unlike states with green mandates, Arizona essentially has none. Instead, our utilities, like many around the country, have self-imposed commitments to go “Net Zero” by 2050. To meet that target, they have planned to shut down all coal generation in the state by 2032 and plan to build out almost exclusively solar, wind, and battery storage to meet an expected explosive growth in demand, at a cost of tens of billions of dollars. So it is no surprise that like much of the rest of the country, Arizona is facing an energy crisis.

Taking a look at our largest regulated utilities (APS, TEP, and UNS) and the largest nonprofit utility, SRP, future plans paint an alarming picture. Combined, over the next 15 years, these utilities expect to see demand increase from 19,200 MW to 28,000 MW. For reference, 1,000 MW of electricity is enough to power roughly 250,000 homes. To meet that growth in demand, however, Arizonans will only get a net increase of 989 MW of reliable generation (coal, natural gas, and nuclear) compared to 22,543 MW (or nearly 23 times as much) of intermittent solar, wind, and battery storage.

But what about all of the new natural gas coming into the state? The vast majority of it will be eaten up just to replace existing coal resources, not to bring additional affordable energy to the grid. For example, the SRP board recently voted to approve the conversion of their Springerville coal plant to natural gas by 2030, which follows an earlier vote to convert another of their coal plants, Coronado, to natural gas by 2029. This coal conversion trap leaves ratepayers with the same amount of energy as before, eating up new natural gas capacity, without the benefit of more electricity.

So, while the Arizona utilities plan to collectively build an additional 4,538 MW of natural gas capacity over the next 15 years, at the same time they will be removing -3,549 MW (all of what is left on the grid today) of coal. And there are no plans for more nuclear capacity anytime soon. Instead, to meet their voluntary climate commitments, utilities plan to saddle ratepayers with the cost and resultant blackouts of the green new scam.

It’s no surprise then that Arizona’s largest regulated utilities, APS and TEP, are seeking double digit rate hikes next year. It’s not just Arizona. Excel customers in Colorado (with a 100% clean energy commitment) and in Minnesota (also with a 100% clean energy commitment) are facing nearly double-digit rate hikes. The day before Thanksgiving, PPL customers in Rhode Island (with a state mandate of 100% renewable by 2033) found out they may see rate hikes next year. Dominion (who has a Net Zero by 2050 commitmentwanted to raise rates for customers in Virginia by 15%. Just last month, regulators approved a 9% increase. Importantly, these rate increases are to recover costs for expenses incurred years ago, meaning they are clearly to cover the costs of the energy “transition” supercharged under the Biden administration, not from increased demand from data centers and AI.

It’s the same story around the country. Electricity rates are rising. Reliability is crumbling. We know the cause. For generations, we’ve been able to provide reliable energy at an affordable cost. The only variable that has changed has been what we are choosing to build. Then, it was reliable, dispatchable power. Now, it is intermittent sources that we know cost more, and that we know cause blackouts, all to meet absurd goals of going 100% renewable – something that no utility, state, or country has been able to achieve. And we know the result when they try.

This crisis can be avoided. Trump has laid out the plan to unleash American Energy. Now, it’s time for utilities to drop their costly green new scam commitments and go back to building reliable and affordable power that generations to come will benefit from.

Greg Blackie, Deputy Director of Policy at the Arizona Free Enterprise Club. Greg graduated summa cum laude from Arizona State University with a B.S. in Political Science in 2019. He served as a policy intern with the Republican caucus at the Arizona House of Representatives and covered Arizona political campaigns for America Rising during the 2020 election cycle.

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The $50 Billion Question: EVs Never Delivered What Ottawa Promised

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Marco Navarro-Génie's avatar Marco Navarro-Génie

Beware of government promises that arrive gift-wrapped in moral certainty.

The pattern repeats across the sector: subsidies extracted, production scaled back, workers laid off, taxpayers absorbing losses while executives collect bonuses and move on, and politicians pretend that it never happened. CBC isn’t asking Justin Trudeau, Katherine McKenna or Steven Guilbeault any questions about it. They are not asking Mark Carney.

Buy an electric vehicle, they said, and you will save the planet, no questions asked. Justin Trudeau and several of his ministers proclaimed it from podiums. Environmental activists, often cabinet members, chanted it at rallies. Automotive executives leveraged it to extract giant subsidies. For over a decade, the message never wavered: until $50 billion in public money disappeared into corporate failures, and the economic wreckage became impossible to ignore.

Prime Minister Mark Carney, himself a spokesperson for the doomsday culture, inherited the policy disaster from Trudeau and still clings to the wreckage. The 2026 EV sales target sits suspended, a grudging acknowledgment that reality refused to cooperate with radical predictions and Ottawa’s mandates. Yet the 2030 and 2035 targets remain federal law, monuments to a central-planning exercise that delivered the opposite of what it promised.

Their claims were never quite true. Electric vehicles were pure good. They were marketed as unconditionally cleaner than conventional cars, a transformation so obviously beneficial that questioning it invited accusations of climate denial. Government messaging suggested switching to an EV meant immediate environmental virtue. The nuance, the conditions, and the caveats were conveniently omitted from the government sales pitch that justified tens of billions of your money into subsidies for foreign EV manufacturing and corporate advancement.

The Reality Ottawa Is Hiding

Research documented the conditional nature of EV benefits for over a decade, yet Ottawa proceeded as if the complexity didn’t exist. Studies from China, where coal dominates electricity generation, showed as early as 2010 that EVs in coal-dependent regions had “very limited benefits” in reducing emissions compared to gasoline vehicles. In Northern China, where electricity generation is over 80% coal-based, EVs could produce lifecycle emissions comparable to or even higher than those of conventional cars. A 2015 Chinese study found that EVs generated lifecycle emissions that were only 18% lower than those of gasoline vehicles, compared to 40-70% reductions in regions with cleaner grids.

Volvo began publishing transparent lifecycle assessments for its first EV in 2019, making it the first major automaker to document the significant upfront emissions from battery production publicly. Their 2021 C40 Recharge report, released during the COP26 climate summit in Glasgow, revealed that manufacturing an EV produces 70% more emissions than building a comparable conventional vehicle. But there are no CBC reports about that. The Volvo report showed that an EV charged on a coal-heavy global grid required 68,000 to 110,000 miles of driving to break even with a conventional car, potentially more than half the vehicle’s usable lifetime. For drivers with low annual mileage in regions with dirty electricity grids, that breakeven point could take six to nine years to reach, if ever.

Battery manufacturing location proved enormously consequential. Production in China, powered by coal, generates 60-85% higher emissions than manufacturing in Europe or the United States. Yet Canadian subsidies flowed to companies regardless of where batteries were made or where vehicles would be charged. The federal government committed over $50 billion without requiring the environmental due diligence that should precede such massive public investment.

The Canadian government never acknowledged Volvo’s findings. Not once. A search of federal policy documents, ministerial statements, and environmental assessments from 2019 forward reveals no mention of the lifecycle complexities Volvo documented. Ottawa’s silence on inconvenient research speaks loudly about how ideology trumped evidence in shaping EV policy.

You want to build a pipeline in Canada. There will be 8 to 10 years of red tape and environmental impact assessments. But if you say you want to make EVs, Laurentian provincial premiers and the feds will bend over backwards. They handed over billions while the economy and social conditions in their cities decayed.

The environmental promise was conditional: clean electricity grids, high annual mileage, manufacturing in regions with low-carbon energy, and vehicles driven long enough to offset the massive carbon debt from battery production. Remove those conditions, and the environmental case collapses. The subsidies, however, remained unconditional.

The Subsidies Flow, The Companies Fail

Corporate casualties now litter the landscape. Northvolt received $240 million in federal subsidies to build a Quebec battery plant before filing for bankruptcy protection in November. Lion Electric, Quebec’s homegrown EV manufacturer, burned through $100 million in government support before announcing massive layoffs and production cuts. Arrival, which secured subsidies for its electric van facility, collapsed entirely, leaving taxpayers with nothing but broken promises.

Stellantis and LG Energy Solution extracted $15 billion, the most extensive corporate handout in Canadian history, for their Windsor battery plant. Volkswagen secured $13 billion for St. Thomas. Provincial governments layered on additional incentives. The public investment dwarfed any plausible return, yet the money kept flowing based on environmental claims the government either never bothered to verify or suppressed from its own documents and reports.

Despite this flood of subsidies and regulatory coercion, Canadian consumers rejected the offering. Even with massive incentives, EVs accounted for only 15% of new vehicle sales in 2024, far short of the mandated 20% target for 2026, let alone the 60% demanded by 2030. When federal subsidies ended in early 2025, sales collapsed to 9%, revealing the limited consumer demand. Dealer lots overflow with unsold inventory. Manufacturers scaled back production plans. The market spoke; Ottawa is only half listening.

The GM plant in Oshawa serves as a cautionary tale. Thousands of jobs lost. Promises of green manufacturing jobs evaporated. Workers who believed government assurances that EV mandates would secure their livelihoods found themselves unemployed as companies redirected production or collapsed entirely. The pattern repeats across the sector: subsidies extracted, production scaled back, workers laid off, taxpayers absorbing losses while executives collect bonuses and move on, and politicians pretend that it never happened. CBC isn’t asking Justin Trudeau, Katherine McKenna or Steven Guilbeault any questions about it. They are not asking Mark Carney.

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The Central Planning Failure

The EV disaster illustrates why economies run by political offices never succeed. Friedrich Hayek observed that “The curious task of economics is to demonstrate to men how little they really know about what they imagine they can design.” Politicians and bureaucrats in Ottawa do not possibly possess the dispersed knowledge embedded in millions of individual economic decisions. But they think that they do.

Markets aggregate information that no central planner can access. Consumer preferences for vehicle range, charging convenience, and total cost of ownership. Regional variations in electricity generation and the pace of grid decarbonization. Battery technology improvements and supply chain vulnerabilities. Resource constraints and mining capacity. These factors interact in ways too complex for any cabinet planning committee to comprehend, yet Ottawa presumed to mandate outcomes a generation in advance.

Federal ministers with no experience in automotive manufacturing or battery chemistry presumed to direct the transformation of a trillion-dollar industry. Career bureaucrats drafted regulations determining which vehicles Canadians could purchase years hence, as if they possessed prophetic knowledge of technological development, grid decarbonization rates, consumer preferences, and global supply chains.

The EV mandate attempted to force a technological transition. It was an economic coup. Environmental claims proved conditional at best. Billions in subsidies flowed to failing companies. Taxpayers absorbed losses while corporations extracted rents and walked away. It worked well for the corporations, but the coup failed Canadians and Canadian workers. They are not building back better.

Green ideology provided perfect cover for this overreach. Invoke climate emergency, and fiscal responsibility vanishes. Question subsidies and you’re labelled a denier. Point out that environmental benefits depend on specific conditions, and you’re accused of spreading misinformation. The rhetorical shield, aided and abetted by a complicit media unable to see past its own financial interests, allowed government to bypass scrutiny that should attend any massive industrial policy intervention.

The Trust Deficit

As Canadians learn that EV environmental benefits depend heavily on electricity sources and driving patterns, as they watch subsidized companies collapse, as they discover how thoroughly the promise was oversold and how completely Ottawa ignored contrary evidence, trust in government erodes. This badly needed skepticism will spread beyond EVs and undermine legitimate government functions.

It would be good if future government claims about environmental policy face rising skepticism. Corporations wrapping themselves in green rhetoric may be viewed as con artists. Environmental activists who championed these policies may see their credibility destroyed. When citizens conclude their government systematically misled them about costs, benefits, and basic facts while suppressing inconvenient research, liberal democracy itself suffers. But that may not happen at all in Laurentian LaLa-land or in the Pacific Lotusland.

Over fifty billion dollars are distributed among local and foreign industrialists, while tens of thousands live in tents in Laurentian cities.

The EV debacle demonstrates that overselling policy benefits, suppressing complexity, and using ideology to short-circuit debate produce a backlash far worse than honest acknowledgment of nuance would have. The damage compounds when governments commit billions based on conditional environmental claims they never verified, then remain silent when industry-leading manufacturers publish data revealing those conditions.

The Path Forward

Canada needs a full repeal of the EV mandate and a complete retreat from Ottawa directing market decisions. The EV law must be struck, not merely paused. The 2030 and 2035 targets must be abandoned entirely. No new subsidies for EV production (or any other production). No bailouts for failed battery plants. No additional funds for charging infrastructure. And absolutely no subsidies for conventional or hybrid vehicle production justified by the same environmental complexity that should have prevented EV mandates in the first place.

Let markets determine which technologies Canadians choose. If EVs deliver genuine value for specific consumers in specific circumstances—those with clean electricity grids, high annual mileage, and long vehicle ownership timelines—those consumers will buy them without mandates or subsidies. If hybrids or improved conventional vehicles better serve other consumers’ needs, manufacturers will produce them without government direction.

The aggregated wisdom of millions of economic actors making decisions based on their actual circumstances will produce better outcomes than any planning committee in Ottawa. Some Canadians will find EVs deliver environmental and financial benefits. Others will not. Both conclusions can be correct simultaneously, a nuance Ottawa spent $50 billion refusing to acknowledge.

Markets work because no one has to know everything. Central planning fails because someone must. I wish I could say that Ottawa has learned this lesson the expensive way. Or whether Laurentians will remember it at the next election. Or whether the same politicians and bureaucrats who delivered this disaster will identify the next technology to mandate and subsidize, armed with new promises that reality will eventually expose as conditional at best.

But let’s keep our dreams in check. It seems more likely, given their ideological make-up and propensities for certainty, that low-information Laurentian and Pacific Coast voters will go right for the next green-washed fantasy that the feds and provincial governments will put in front of them, provided it is coiled into a catchy slogan.


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