Olympia Trust – Tax Court of Canada finds that trustee for self-directed RRSPs was liable for failure to withhold under s. 116

A Canadian trust company, which was the trustee for self-directed RRSPs that had purchased shares from non-residents without withholding or receiving s. 116 certificates, was found by Bocock J to be the "purchaser" for s. 116(5) purposes rather than the annuitants, i.e., it was on the hook as the shares were taxable Canadian property.

Neal Armstrong. Summary of Olympia Trust Company v. The Queen, 2014 TCC 372 under s. 116(5).