If my application for registration is selected for review, can “deemed” registration under current subsection 147.1(3) of the Income Tax Act (the “Act”) still occur?
Yes. The law has not changed and subsection 147.1(3) will continue to deem registration in the circumstances described in that provision. Plans submitted for registration in the manner prescribed by subsection 8512(1) of the Income Tax Regulations (the “Regulations”), and that are not selected for review, will receive a letter confirming registration of the plan in accordance with paragraph 147.1(2)(c) of the Act. Plans submitted for registration in the manner prescribed by subsection 8512(1) of the Regulations, and that are selected for review, will receive a letter confirming that an application had been made in a prescribed manner and that the plan has been deemed registered under subsection 147.1(3) of the Act. With fewer plans subject to review before registration, however, there will be fewer deemed registrations under the new process. For more information about deemed registration, please refer to the Registered Pension Plan Guide at www.cra-arc.gc.ca/E/pub/tg/t4099/t4099-05e.pd
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