On July 22, 2016 (the Announcement Date), the Department of
Finance released a package of draft legislative amendments that
includes proposed changes to the existing GST/HST rules under the
Excise Tax Act (the ETA) relating to pension
plans.1 Most of these changes concern pension plan
structures that include a "master pension entity," which
is newly defined to be a corporation or trust described in
paragraph 149(1)(o.2) or (o.4) of the Income Tax Act, one
or more shares or units of which are owned by a "pension
entity" of the pension plan, as defined in subsection 123(1)
of the ETA.2
The proposed changes will, in effect, extend the existing deemed
supply rules3 and rebate4 provisions
applicable to plan-related expenses incurred in respect of pension
entities to apply, in a similar manner, to such expenses incurred
in respect of master pension entities as well. The main aspects of
these proposed amendments are summarized below. All statutory
references below are to
