Words and Phrases - "contingent beneficiary"
Underused Housing Tax Notice UHTN15, Questions and Answers About the Underused Housing Tax, 17 April 2023
Bare trust can be a specified Canadian trust (para. 1.18)
- A corporation holding title to a residential property in Canada as bare trustee would be required to file a return, but its holding may be exempted if the trust is a specified Canadian trust.
Beneficiaries do not include contingent beneficiaries (para. 4.2)
- The reference to beneficiary does not include any contingent beneficiary of the trust (being “a person who may or will benefit if a primary beneficiary dies or otherwise loses rights as beneficiary”).
Look through trust beneficiary to its beneficiaries (para. 4.4)
- As a trust is not a person for UHT purposes, it is likely that where a trust is a beneficiary of another trust, the beneficiaries of the first trust are to be treated as beneficiaries of the second trust.
Words and Phrases
contingent beneficiary