CRA confirms that a Canadian registered charity beneficiary of a non-resident trust does not engage the s. 94 rules

CRA noted that, since the definition of a “resident beneficiary” in s. 94(1) excludes an “exempt person,” the inclusion in the potential beneficiaries of a non-resident trust of Canadian registered charities would not by itself cause the s. 94 rules to apply to that trust.

Neal Armstrong. Summary of 20 June 2023 STEP Roundtable, Q.6 under s. 94(1) – resident beneficiary.