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One-time AIR filing extension for Ontario IPPs and designated plans

One-time AIR filing extension for Ontario IPPs and designated plans

July 15, 2021

In December 2020, Ontario amended its Pension Benefits Act (PBA) to enable the Financial Services Regulatory Authority of Ontario (FSRA) to permit certain individual pension plans (IPPs) and designated plans (DPs) to file an election to be exempted from the Ontario Pension Benefits Act (PBA) and associated regulations.

Pension plans, including IPPs and DPs, are required to file an Annual Information Return (AIR), with the Canada Revenue Agency (CRA) and, provincial regulators such as FSRA, if the plan is registered under provincial pension legislation.  The CRA has established a joint filing process with FSRA for AIRs, with a 9-month filing deadline for defined benefit pension plans.

Once a plan ceases to registered with FSRA, the AIR must be filed directly with the CRA.  The CRA Form T244, Annual Information Return, is due 180 days after the plan’s fiscal year end. This shorter deadline has created difficulties for Ontario IPPs and DPs that have become exempt from the PBA and are used to the 9-month filing deadline.

On June 25, 2021, the Registered Plans Directorate of the CRA indicated that it will provide a one-time filing extension for affected Ontario IPPs and DPs with a year-end that falls between December and March. The filing deadline for the Form T244, Annual Information Return is extended to September 30, 2021.

In future years, all IPPs will be required to respect the regular CRA deadline (i.e., 180 days).