CRA recommends that executors of non-resident estates that could have Canadian tax liabilities apply for a clearance certificate
A former resident of Canada (and after her death, her non-resident estate, which had exclusively non-resident beneficiaries) received CPP, interest and RRSP/RRIF payments from Canadian sources. Would the non-resident executors be required under s. 159(2) to apply (pursuant to a Form TX19 request) for CRA to issue a clearance certificate?
CRA responded with a somewhat generic answer that might have served equally for resident executors (i.e., they could face personal liability for unpaid taxes of the deceased if they did not do so).
CRA also reiterated its position that there is an obligation of the non-resident beneficiaries who are disposing of capital interests in the estate that are taxable Canadian property, as well as of the estate if it is distributing taxable Canadian property, to apply for a s. 116 certificate.