David Carolin, Manu Kakkar, "Estate Plans, Trusts, and Dividends: Is There a Gap Here?", Tax for the Owner-Manager, Vol. 21, No. 1, January 2021, p. 1

Deferral opportunity arising from CRA’s position that s. 104(19)-designated dividend is not received for s. 186(1)(b) purposes until year end of...

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deferral (or other) opportunities arising from CRA’s position that s. 104(19)-designated dividend is not received until year-end of trust

CRA’s position (e.g., in 2016-0647621E5 and 2013-0495801C6) is that a dividend designated under s. 104(19) by a trust to a beneficiary is not...

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