In 2014-0531441E5, the CRA confirmed that payments to a US resident under an unfunded long-term disability (LTD) plan by a Canadian employer would be considered salary. As such, the payment would be subject to employment-related withholdings in Canada (under s. 153). These payments would also be considered pension income as defined in paragraph 3 of Article XVIII of the Canada-US tax treaty (Treaty). Accordingly, the US resident could file a tax return in Canada and request a refund of the amount withheld in Canada, to the extent such amount exceeded the maximum 15% rate specified in Article XVIII of the Treaty.