Newsletter no. 95-4, New Filing Requirements for the Registered Pension Plan Information Return

May 15, 1995

This newsletter provides information on a new joint annual information return (AIR) and describes other changes in the requirements for filing Form T244, Registered Pension Plan Annual Information Return.

The changes are being made as part of ongoing initiatives by Canada Revenue Agency and the Canadian Association of Pension Supervisory Authorities to reduce the administrative burden on pension plan administrators and the cost of regulatory programs. We have been working with pension supervisory authorities to develop a joint AIR. We are now able to accommodate the filing of a single, joint return with certain pension supervisory authorities. We are continuing to develop joint filing with all supervisory authorities.

We have co-ordinated the filing deadline and reporting period for the Canada Revenue Agency AIR with AIR filing requirements under provincial and federal pension benefits legislation. We are amending the filing deadline in the Income Tax Regulations to make joint filing possible. The changes to the Regulations apply to plans with a plan year-end after December 30, 1994, which is the date we began administering the changes.

Also, we have shortened and simplified the Canada Revenue Agency AIR to make it easier to complete.

Joint return

Each of the pension supervisory authorities that is participating in the joint filing program has revised its annual information return to include Canada Revenue Agency information needs. The supervisory authority's AIR forms the main part of the joint return. When Canada Revenue Agency and the supervisory authority have common requirements, e.g., plan identification, number of active members, contributions, etc., questions on this information will appear only on the main form. Any information required only by Canada Revenue Agency will be collected on a schedule. Questions on the Canada Revenue Agency schedule may vary between supervisory authorities, since each supervisory authority has different information requirements. Canada Revenue Agency obtains the same information in total from the main form and the schedule for each participating authority.

Participating pension supervisory authorities

The participating supervisory authority with which you file an AIR will send you a joint return to complete before your filing deadline. When you file the joint return with the pension supervisory authority, you will satisfy the requirement to file an annual information return under the Income Tax Act and under the relevant pension benefits legislation.

The current participating authorities are:

• the Superintendent of Pensions, Province of Nova Scotia;
• the Superintendent of Pensions, Province of New Brunswick;
• the Superintendent of Pensions, Province of Ontario;
• the Superintendent of Pensions, Province of Manitoba; and
• the Superintendent of Pensions, Province of British Columbia.

We will announce new participating authorities as soon as we develop joint returns with other pension supervisory authorities.

The joint return was not immediately available in all participating jurisdictions on December 31, 1994. In particular, the Pension Commission of Ontario expects to be mailing out its first joint return by the end of the first quarter in 1995. Until then, the Pension Commission of Ontario will send you an AIR for Ontario only, and we will send you the Canada Revenue Agency AIR. You will have to file both returns separately. Once you receive a joint return from the participating authority, you will no longer have to file separately with Canada Revenue Agency.

We are trying to make the transition to the joint return as smooth as possible.

Canada Revenue Agency and pension supervisory authorities have been active over the last several months matching plan information. The aim is to eventually use a single number, the seven-digit Canada Revenue Agency number, as the plan registration number. On some joint returns, we are asking for both the Canada Revenue Agency and the supervisory authority's number. This will allow us to make sure the matched data is accurate.

In the initial year that Canada Revenue Agency phases in a joint return, there could be some overlap in the returns you receive. You might receive two returns: a joint return from a participating authority, and one from Canada Revenue Agency. You only need to complete and file the joint return with the participating authority. However, if you do not receive a joint return from the participating authority, you have to file a Canada Revenue Agency AIR with us, and a separate AIR with the participating authority.

Non-participating pension supervisory authorities

You will continue to file the AIR for a non-participating authority with that authority, and the Canada Revenue Agency AIR with us. If you file with a non-participating authority, you should have received the Canada Revenue Agency AIR early in March 1995.

Filing deadline

We have changed the filing deadline for the Canada Revenue Agency AIR for all plans.

• If you file with a participating authority, file the joint return by the date set by the participating authority.
• If you file with a non-participating authority, file a Canada Revenue Agency AIR no later than 180 days after the plan year-end.

We have also changed the reporting period to correspond with the reporting period under pension benefits legislation. The Canada Revenue Agency AIR now asks for information based on the fiscal year of the plan, not the calendar year.

The new filing deadlines apply to plan year-ends occurring after December 30, 1994. Participating authorities (with the exception of Ontario as previously mentioned) will send you a joint return to complete if your plan has a fiscal year-end of December 31, 1994, or later.

You have to file the Canada Revenue Agency AIR on a calendar-year basis for 1994 if your plan has a fiscal period ending on December 31, 1994. However, you will not have to file on a calendar-year basis for 1994 if your plan has a fiscal period ending in 1994 before December 31. You have to file a Canada Revenue Agency AIR for such a plan for the first fiscal period of the plan that ends after December 30, 1994. For example, if you file with a non-participating authority and the plan year-end is March 31, 1995, you have to file a Canada Revenue Agency AIR not later than 180 days after that date; that is, by September 27, 1995. This return will cover the plan fiscal period from April 1, 1994, to March 31, 1995.

Note: If you file with a participating authority and the plan year-end is

March 31, 1995, you have to file a joint return for the plan fiscal period from April 1, 1994, to March 31, 1995, by the date the participating authority sets.

Access to information

The confidentiality provisions of the Income Tax Act protect the information that you provide to us. The pension supervisory authorities who are participating in this program will make the information available to us, but not to any other person.

Where to get help

For a copy of an AIR to file with a pension supervisory authority, or for questions on an AIR relating to pension benefits legislation, please contact the pension supervisory authority.

For more information on the Canada Revenue Agency AIR go to Savings and pension plan administration.

By telephone

Toll-free in Canada and the United States: 1-800-267-3100.

If you are calling from outside of Canada or the United States, call us collect at 613-221-3105. The Registered Plans Directorate accepts collect calls.

By mail and courier

Due to a building refit spanning multiple years, the Registered Plans Directorate’s mailing address has been temporarily changed. Please use the following address for all correspondence until further notice:

Registered Plans Directorate
Canada Revenue Agency
2215 Gladwin Cres
Ottawa ON  K1B 4K9

We welcome feedback on this bulletin. Send comments by email to RPD.LPRA2@cra-arc.gc.ca.