CRA indicates that a s. 116 certificate can cover multiple estate distributions to a non-resident beneficiary

CRA indicated that where the executor or trustee of an estate or trust will be making several capital distributions to a non-resident beneficiary (whose capital interest in the trust or estate constitutes taxable Canadian property) over multiple years, the beneficiary can apply now for a s. 116 certificate (along with payment of the tax to cover the gain on the disposition of the capital interest - or the provision of security therefor). After verification, CRA will issue a certificate of compliance. The certificate limit is based on the estimated total distributions, so that the capital distributions over time can be received by the beneficiary up to the certificate limit.

If the facts change, another T2062 application can be made with an additional payment or security to cover any increase in the tax payable. Upon review, the CRA will then issue a revised certificate.

Neal Armstrong. Summary of 17 June 2025 STEP Roundtable, Q.6 under s. 116(2).