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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].

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Canada Can Finally Profit From LNG If Ottawa Stops Dragging Its Feet

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From the Frontier Centre for Public Policy

By Ian Madsen 

Canada’s growing LNG exports are opening global markets and reducing dependence on U.S. prices, if Ottawa allows the pipelines and export facilities needed to reach those markets

Canada’s LNG advantage is clear, but federal bottlenecks still risk turning a rare opening into another missed opportunity

Canada is finally in a position to profit from global LNG demand. But that opportunity will slip away unless Ottawa supports the pipelines and export capacity needed to reach those markets.

Most major LNG and pipeline projects still need federal impact assessments and approvals, which means Ottawa can delay or block them even when provincial and Indigenous governments are onside. Several major projects are already moving ahead, which makes Ottawa’s role even more important.

The Ksi Lisims floating liquefaction and export facility near Prince Rupert, British Columbia, along with the LNG Canada terminal at Kitimat, B.C., Cedar LNG and a likely expansion of LNG Canada, are all increasing Canada’s export capacity. For the first time, Canada will be able to sell natural gas to overseas buyers instead of relying solely on the U.S. market and its lower prices.

These projects give the northeast B.C. and northwest Alberta Montney region a long-needed outlet for its natural gas. Horizontal drilling and hydraulic fracturing made it possible to tap these reserves at scale. Until 2025, producers had no choice but to sell into the saturated U.S. market at whatever price American buyers offered. Gaining access to world markets marks one of the most significant changes for an industry long tied to U.S. pricing.

According to an International Gas Union report, “Global liquefied natural gas (LNG) trade grew by 2.4 per cent in 2024 to 411.24 million tonnes, connecting 22 exporting markets with 48 importing markets.” LNG still represents a small share of global natural gas production, but it opens the door to buyers willing to pay more than U.S. markets.

LNG Canada is expected to export a meaningful share of Canada’s natural gas when fully operational. Statistics Canada reports that Canada already contributes to global LNG exports, and that contribution is poised to rise as new facilities come online.

Higher returns have encouraged more development in the Montney region, which produces more than half of Canada’s natural gas. A growing share now goes directly to LNG Canada.

Canadian LNG projects have lower estimated break-even costs than several U.S. or Mexican facilities. That gives Canada a cost advantage in Asia, where LNG demand continues to grow.

Asian LNG prices are higher because major buyers such as Japan and South Korea lack domestic natural gas and rely heavily on imports tied to global price benchmarks. In June 2025, LNG in East Asia sold well above Canadian break-even levels. This price difference, combined with Canada’s competitive costs, gives exporters strong margins compared with sales into North American markets.

The International Energy Agency expects global LNG exports to rise significantly by 2030 as Europe replaces Russian pipeline gas and Asian economies increase their LNG use. Canada is entering the global market at the right time, which strengthens the case for expanding LNG capacity.

As Canadian and U.S. LNG exports grow, North American supply will tighten and local prices will rise. Higher domestic prices will raise revenues and shrink the discount that drains billions from Canada’s economy.

Canada loses more than $20 billion a year because of an estimated $20-per-barrel discount on oil and about $2 per gigajoule on natural gas, according to the Frontier Centre for Public Policy’s energy discount tracker. Those losses appear directly in public budgets. Higher natural gas revenues help fund provincial services, health care, infrastructure and Indigenous revenue-sharing agreements that rely on resource income.

Canada is already seeing early gains from selling more natural gas into global markets. Government support for more pipelines and LNG export capacity would build on those gains and lift GDP and incomes. Ottawa’s job is straightforward. Let the industry reach the markets willing to pay.

Ian Madsen is a senior policy analyst at the Frontier Centre for Public Policy.

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The Climate-Risk Industrial Complex and the Manufactured Insurance Crisis

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We’ve all seen the headlines — such as the below — loudly proclaiming that due to climate change the insurance industry is in crisis, and even that total economic collapse may soon follow. For instance, since 2019, the New York Times, one of the primary champions of this narrative, has published more than 1,250 articles on climate change and insurance.

Climate advocates have embraced the idea of a climate-fueled insurance crisis as it neatly ties together the hyping of extreme weather and alleged financial consequences for ordinary people. The oft-cited remedy to the claimed crisis is, of course, to be found in energy policy: “The only long-term solution to preserve an insurable future is to transition from fossil fuels and other greenhouse-gas-emitting industries.”

However, it is not just climate advocates promoting the notion that climate change is fundamentally threatening the insurance industry. A climate-risk industrial complex has emerged in this space and a lot of money is being made by a lot of people. The virtuous veneer of climate advocacy serves to discourage scrutiny and accountability.

In this series, I take a deep dive into the “crisis,” its origins, its politics, and its tenuous relationship with actual climate science.¹ Today, I kick things off by sharing three fundamental, and perhaps surprising, facts that go a long way to explaining why insurance prices have increased and who benefits:

  • Property/casualty insurance is raking in record profits;
  • Insurance underwriting returns vary year-to-year but show no trend;
  • “Climate” risk assessments are unreliable and a cause of higher insurance prices.

Grab a cup of coffee, settle in, and let’s go . . .

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Property/casualty insurance is raking in record profits

This year is shaping up to be an extremely profitable year for the property/casualty (P/C) insurance industry. In a report covering the first six months of 2025, the National Association of Insurance Commissioners (NAIC) shares the good news (emphasis added):

Despite heavy catastrophe losses, including the costliest wildfires on record, the U.S. Property & Casualty (P&C) industry recorded its best mid-year underwriting gain in nearly 20 years.

In the second half of 2025, returns got even better for the P/C industry. According to a new report from S&P Global Intelligence, as reported by Carrier Management (emphases added):

For U.S. P/C insurers, it just doesn’t get any better than this. . . With a combined ratio of 89.1 for third-quarter 2025, the U.S. property/casualty insurance industry had its best quarter in at least a quarter of a century—and maybe longer, S&P Market Intelligence said.

Taking a longer view, the extremely profitable 2025 follows significant industry profitability in 2023 and 2024, according to the National Association of Insurance Commissioners (NAIC), as shown in the figure below.

P/C industry profitability 2015 to 2024. Source: NAIC.

What accounts for the high profits?

The NAIC explains:

Strong premium growth, driven largely by rate increases, coupled with abating economic inflation . . . Net income nearly doubled compared to last year, attributed to the underwriting profit and healthy investment returns.

Below, I’ll pick up the issue of rate increases and explore one big reason why they have occurred.

If there is a P/C insurance crisis, it may be in figuring out how to explain its impressive returns at the same time that the climate lobby is telling everyone that the industry is collapsing.

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Insurance underwriting returns vary year-to-year but show no trend

The P/C industry makes money primarily in two ways — underwriting of insurance policies and investment income. Typically, insurance companies seek to break even, or lose little, on insurance underwriting and earn profits on investment income.

Warren Buffet, in his 2009 letter to Berkshire Hathaway shareholders, explained concisely how the P/C industry works:

Our property-casualty (P/C) insurance business has been the engine behind Berkshire’s growth and will continue to be. It has worked wonders for us. We carry our P/C companies on our books at $15.5 billion more than their net tangible assets, an amount lodged in our “Goodwill” account. These companies, however, are worth far more than their carrying value– and the following look at the economic model of the P/C industry will tell you why.

Insurers receive premiums upfront and pay claims later. In extreme cases, such as those arising from certain workers’ compensation accidents, payments can stretch over decades. This collect-now, pay-later model leaves us holding large sums– money we call “float”– that will eventually go to others. Meanwhile, we get to invest this float for Berkshire’s benefit. Though individual policies and claims come and go, the amount of float we hold remains remarkably stable in relation to premium volume. Consequently, as our business grows, so does our float.

If premiums exceed the total of expenses and eventual losses, we register an underwriting profit that adds to the investment income produced from the float. This combination allows us to enjoy the use of free money– and, better yet, get paid for holding it. Alas, the hope of this happy result attracts intense competition, so vigorous in most years as to cause the P/C industry as a whole to operate at a significant underwriting loss. This loss, in effect, is what the industry pays to hold its float. Usually this cost is fairly low, but in some catastrophe-ridden years the cost from underwriting losses more than eats up the income derived from use of float.

The figure below, using data from the Insurance Information Institute, shows the underwriting performance of the P/C industry from 2004 to 2024.

Source: III, adjusted to 2025 dollars via CPI.

The time series shows lots of ups and downs, but no trend — by design, as Buffet explained. There are certainly no signs of an underwriting crisis, much less indications of a coming collapse. The P/C industry looks both well-managed and healthy.

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“Climate” risk assessments are unreliable and a cause of higher insurance prices

Source: NAIC

If profits are high and underwriting is steady, then what then accounts for increasing insurance prices — which, as of the end of 2024, increased 29 consecutive quarters in a row (above)?

A big part of the answer is Climate Change. But not how you might think.

A decade ago, Mark Carney — then Governor of the Bank of England and today Prime Minister of Canada — gave an influential speech titled, Breaking the Tragedy of the Horizon – climate change and financial stability.

Carney argued that the insurance industry was at risk due to changes in the climatology of extreme events that were not properly understood by experts in the industry:

[T]here are some estimates that currently modelled losses could be undervalued by as much as 50% if recent weather trends were to prove representative of the new normal. . . Such developments have the potential to shift the balance between premiums and claims significantly, and render currently lucrative business non-viable.

Coincident with Carney’s 2015 speech, the Bank of England released a report on the impacts of climate change on the insurance industry, and noted that conventional catastrophe modeling did not effectively consider a changing climate. The Bank of England kicked off a longstanding campaign to convince people that extreme weather events were changing dramatically in the near term.

Subsequently, in 2019, the Bank of England required firms to assess their “climate risks.” This guidance was updated last week. In (a coordinated) parallel effort, national and international organizations focused on “climate risk” to the financial sector started multiplying — such as the Climate Financial Risk Forum and the Network for Greening the Financial System.

The climate-risk industry was born circa 2019.

There is an incredible story to be told here (and Jessica Weinkle is the go-to expert), but for today, the key takeaways are that (a) the notion of “climate risk” to finance, including insurance, led to the creation of a “climate risk” industry, and (b) within this industry, a new family of risk assessment vendors emerged, promising to satisfy the new demands for climate risk disclosure and risk modeling.

The Global Association of Risk Professionals (GARP) explains:

As this [“climate risk”] was a new discipline for most financial firms, many turned to third party providers (“vendors”) to help them with different areas of expertise. There are now many physical risk data vendors, which offer a variety of services to financial institutions. While vendor offerings often sound alike — providing projections of how physical risk could evolve for locations across a range of risks and climate scenarios — they can differ significantly in terms of features, approach, or suitability for specific needs, and the underlying models that these providers use differ in methodology and assumptions.

GARP just published an incredibly important study that assessed how 13 different “climate risk” vendors modeled physical risk and risk of loss across 100 individual structures around the world.²

The results are shocking — given how they are used in industry, but should not be surprising — given what we know about modeling.

There is absolutely no consensus across vendors about “climate risk” in terms of either physical risks or risks of loss.

The figure below shows, for 100 different properties around the world, the differences in modeled 200-year flood risk across the 13 vendors, as refelcted in modeled flood heights. The maximum difference among the properties across vendors is about 12 meters and the median difference is about 2.7 meters — These are huge differences.

Source: GARP 2025

In terms of risk of loss, the models have an even greater spread. The figure below shows that for a modeled 200-year flood, 10 properties are modeled by at least one vendor to have total losses (100%) while another vendor models the same properties to have no losses, under the exact same event. The median difference between minimum and maximum modeled loss ratio is 30% — Another huge number.³

Source: GARP 2025.

Insurance pricing does not scale linearly with increasing modeled loss ratios. Consider that the difference between a modeled 10% loss ratio and a 40% loss ratio (i.e., the 30% median difference across vendors from above) might result in a 10x increase in insurance rates. Risk adverse insurers have incentives to price at the most extreme modeled loss.

Model inaccuracies, unceratinties, spread, and ambiguity are feature not flaws when it comes to making money. “Climate risk” modeling has resulted in a financial windfall not just for the newly created climate analytics industry, but also for insurers and reinsurers who have seen the envelope of modeled losses expand. The need for new models, of questionabl fidelity, are necessary to satisfy industry guidance and government regulators.

The net result has been a seemingly scientific justification for increasing insurance rates.⁴

There are of course real changes in physical risk, exposure, and vulnerability as well as the regulatory and political contexts within which the P/C industry must operate. The discipline of catastrophe modeling has long integrated these factors to assess risks. As insurance policies and reinsurance contracts are typically implemented on a one-year basis, and this well-positioned to incorporate changng perceptions of risk, this series will explore why a new “climate risk” assessment industry was even needed in the first place.

What about that “climate risk”? THB readers will be very familiar with the science of extreme events and climate change, which, as reported here, happens to be consistent with both the Intergovernmental Panel on Climate Change and those in the legacy catastrophe modeling community.

One of those modeling firms, Verisk, gets the last word for today:

We estimate about 1% of year-on-year increases in AAL [Average Annual Loss] are attributable to climate change. Such small shifts can easily get lost behind other sources of systematic loss increase discussed in this report, such as inflation and exposure growth. The random volatility from internal climate variability also dwarfs the small positive climate change signal.

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Comments, questions, discussion, critique — all welcome!

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1 I recommend reading and following my colleague Jessica Weinkle, who is also exploring this same issue.
2 The vendors are: Climate X, Fathom, First Street, ICE, JBA Risk Management, Jupiter Intelligence, Moody’s, MSCI, Planetrics, a McKinsey & Company solution, Riskthinking.AI, S&P Global, Twinn by Haskoning, XDI.
3 If you have been following recent reporting on Zillow and its climate risk scores, the new GARP report shows undeniably that these scores are largely meaningless in terms of actually quantifying risks.
4 There are of course many other complexities and the P/C industry does indeed face real challenges — including the changing nature of physical risk, risk of loss, and the politics of each. See, for instance this THB post on California’s insurance crisis.

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