Michael N. Kandev, Matias Milet, "Foreign Trusts", 2017 Annual CTF Conference draft paper

Summary Under
Tax Topics - Income Tax Act - Section 94 - Subsection 94(2) - Paragraph 94(2)(k.1)

Potential application where foreign company funds a foreign trust to buy shares of foreign parent before their transfer to Canadian employees (p....

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Summary Under
Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) - Paragraph 94.1(1)(b)

Main-reason test generally not met for foreign commercial trusts (pp. 19-20)

“[N]on-resident entity” is defined, at subsection 94.1(2), as...

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Summary Under
Tax Topics - Income Tax Act - Section 94.2 - Subsection 94.2(3)

Whether s. 104(13) inclusion test is satisfied in case of foreign trust (p. 21)

[S]ubsection 94.2(3) provides for a deduction in computing the...

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