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. 126 with respect to such tax (although they may apply directly to the U.K. Inland Revenue for a refund, which refund would be included in their income when received).

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 income when they receive such refund.