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Frank Stokes' Submission in Response to Finance Canada's Regulatory Framework for Federally Regulated Defined Benefit Pension Plans consultation:

Dear Sirs;

This is my input in response to your Consultation on Private Defined Benefit Pension�Plans.

CPP/QPP allows pension splitting (they call it "sharing" when done within an enduring marriage), and the administrators�inform CPP/QPP recipients in�the literature that�this can reduce their income tax.

It seems odd that CPP/QPP is the only sort of pension in Canada that allows such splitting.� It means that those who have little or no�CPP/QPP pension�among their retirement income are at a tax disadvantage.� This is�clearly unfair.

I realize that it was probably not the primary intention of the CPP/QPP administrators to allow recipients to save income taxes by splitting ("sharing") their benefits, but rather to put benefits directly into the hands of any low-pensioned or non-pensioned spouse.� And perhaps the advertisement of the tax saving is only done�to encourage the higher-pensioned spouse to actually sign over benefits to the lower-pensioned spouse.� But regardless of the motivation or intent of the administrators, the situation created by the exclusivity of benefit splitting for CPP/QPP recipients constitutes a real and unfair tax disadvantage for many other taxpayers who cannot do such, or as much,�splitting due to the non-assignment rule of the Income Tax Act.

I recommend that the government immediately correct this unfair situation by allowing all sorts of pensions (and other�retirement income, to be fair) to be split for income tax purposes.

Such a change need not create�extra work�for retirement income�payers (sending separate, balanced payments the way CPP/QPP does) , because�the government�could simply�provide the option to split retirement income on the income tax return form.

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You may publish this submission.

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Frank Stokes

Munster, Ontario