Waiving the Requirement to File a Registered Pension Plan Annual Information Return for an Inactive Plan
In this newsletter, we advise that, as the plan administrator of a registered pension plan, you do not have to file a Form T244, Registered Pension Plan Annual Information Return, under certain circumstances.
Usually, under section 8409 of the Income Tax Regulations, you have to file this information return each year. As announced in Newsletter 95-4, New Filing Requirements for the Registered Pension Plan Annual Information Return, Revenue Canada accepts joint returns in certain participating provinces, and accepts Form T244 for non-participating provinces. We are waiving this filing obligation in the following circumstances.
- For inactive plans in non-participating provinces, we no longer require Form T244 for the plan years after the plan year the plan became inactive.
- For inactive plans in participating provinces, we no longer require the joint return for the plan years after the plan year the plan became inactive, unless the participating province requires it. You have to complete the Revenue Canada part of a joint return if a participating pension supervisory authority requires you to file an information return for the inactive plan.
These changes are effective for plans with plan year-ends after the date of this newsletter.
A plan is inactive when the plan sponsor terminates the plan and does not pay or transfer out all the plan's assets. A plan usually terminates when:
- the plan sponsor decides to terminate it;
- there are no further current service contributions made to the plan; and
- there are no further benefit accruals.
Some plans can be inactive and still receive past service contributions before the plan completely terminates.
Periodically (e.g., every three years), we may ask the plan administrator to complete a questionnaire to help us monitor the status of an inactive plan and keep our address listings current.
We may also ask a plan administrator to file Form T244 for a particular plan year after the plan year the plan became inactive. We will send our request to the plan administrator in writing. Our request will identify the applicable plan year, and indicate a filing deadline.
If a plan sponsor reactivates an inactive plan, you have to file Form T244 for each plan year that the plan is active. If a participating pension supervisory authority also requires you to file an information return, you can file a joint return with the particular pension supervisory authority instead of using Form T244.
We consider a plan to be reactivated when:
- you make an amendment to the benefits;
- current service contributions; are made by participating employers (whether or not one of them is the plan sponsor) or by plan members, or both;
- you use surplus assets to improve or provide additional benefits under one or more defined benefit provisions of the plan; or
- you allocate forfeitures to members accounts under one or more money purchase provisions of the plan.
As plan administrator, you must notify us in writing within 60 days of the date the last of the plan assets are paid or transferred out of the plan. You will need to give us the final distribution date and the settlement methods. You can notify us by letter or by using Form T244 [Footnote 1].
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Footnotes
- In Pension Reform Update 94-4, Wind-Up Valuation Report, we asked you to file a final Form T244 when the last of the plan assets were paid or transferred out of the plan. This previous requirement to file a final Form T244 is modified by the options set out in this newsletter.
