A Liechtenstein Foundation with a Canadian-resident beneficiary may not be subject to the NRT rules

After affirming its position that a Liechtenstein Foundation "generally will be considered to be a trust for purposes of the Act," CRA accepted that a Liechtenstein Foundation whose sole "beneficiary" was a resident Canadian individual was not subject to the NRT rules in s. 94(3) because the Foundation had no "resident beneficiary," whose definition requires the existence of a "connected contributor."  There was none, as no Canadian resident had ever made a "contribution" (as broadly defined) to the Foundation.

Neal Armstrong.  Summary of 20 August 2015 T.I. 2015-0581681E5 F under s. 94(1) - connected contributor.