CRA indicates that income distributions from a non-resident trust are deemed to be property income

CRA indicated, in light of the wording of ss. 250.1(b) and 104(13), that s. 108(5) extends to non-resident trusts, so that income distributions from a non-resident trust are deemed to be income from property.

Neral Armstrong. Summary of 24 March 2016 Memo 2016-0634191I7 under s. 108(5).