6 May 1991 T.I. (Tax Window, No. 3, p. 27, ¶1240)

The Canadian beneficiaries of a U.K. trust whose trust income is subject to 45% U.K. tax are not entitled to claim a foreign tax credit under s....

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Canadian beneficiaries of a U.K. trust who apply for a refund of 45% U.K. tax to which the trust income was subject, will be treated as earning...

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