GST/HST Technical Information Bulletin B-068 "Bare Trusts" Amended 10 January 2005

[A] bare trust is not engaged in commercial activities and is not entitled to claim ITCs. Instead, the beneficial owners are entitled to claim...

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The determination that a trust is a bare trust generally will result in a conclusion that only the beneficial owner should register and that the...

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....if a trustee performs functions in addition to holding bare legal title, but does so strictly on the instructions of the beneficial owners...

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After discussing whether there is a bare trust, CRA stated:

[S]ections 268 and 269 of the Act provide that, for GST purposes, there will be a...

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