Peter Megoudis, "The Canadian Non-resident Trust Rules and Global Employee Benefit Plan Trusts", Taxation of Executive Compensation and Retirement (Federated Press), Vol. 24, No. 3, October 2012, p. 1583.

Relating awards to non-qualifying services (pp.1587-1588)

The inquiry is thus to determine whether any benefits to be provided by the trust...

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Predominantly single country requirement (p.1586)

Paragraph (g) of the definition of "exempt foreign trust" in subsection 94(1) of the Act...

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Mobile employees/deficits and surpluses (p. 1589)

In many cases, however, mobile employees are providing services for the benefit of different...

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Indirect provision of benefits for employment services provided to Canadian employees (p.1585)

As discussed, the NRT rules only apply if there is...

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Distinguishing trust from agency (p.1584)

The NRT rules only apply to non-resident trusts. They thus presumably do not apply to other...

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