Administrative Policy
19 January 2017 External T.I. 2015-0576751E5 F - Trust, Disposition of depreciable property, Assumption
CRA indicated that the assumption by the beneficiary of debt of a personal trust owing to a bank would not preclude s. 107(2) applying to the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) | s. 13(7)(e) applicable to s. 107(2.1) distribution but not s. 104(5) deemed disposition | 300 |
| Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(2) | s. 107(2) generally available where beneficiary assumes trust debt | 168 |
| Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(2.1) | s. 13(7)(e) applicable to depreciable property distribution | 123 |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | trust cannot have a NAL relationship with itself | 41 |
30 July 2015 External T.I. 2015-0596841E5 - Definition of personal trust
Each of the beneficiaries of an inter vivos trust ("Trust") which is not a unit trust will make an additional contribution of capital to Trust in...
30 April 2003 External T.I. 2002-0156045 - Debt assumed as part/distribution from trust
The assumption of debt of a trust by the beneficiary would not be considered to entail an acquisition of the beneficial interest in the trust for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(2) | 55 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 39 |
IT-385R2 "Disposition of an Income Interest in a Trust"
Articles
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Classification of Trusts for Income Tax Purposes", Chapter 2 of Canadian Taxation of Trusts (Canadian Tax Foundation), 2016.
Increase in value only/debt assumption (p. 59)
[T]he CRA [in 2015-0596841E5] appears to be of the view that a beneficial interest in a trust may...