CRA notes that distributions of trust income for a year deemed to be paid to a non-resident beneficiary 90 days after the year must still be reported on the NR4 for that year

CRA indicated that, where an estate or trust had income payable at its year end of, say, December 31, 2020, to a non-resident beneficiary, but that amount remained unpaid 90 days after that year-end, such amount would be deemed by s. 214(3)(f) to be paid at that time (March 31, 2021), so that the Part XIII withholding tax thereon would be due by April 15, 2021, and both the income and withholding tax would be required to be reported on an NR4 slip issued for the 2020 taxation year.

CRA also noted that this situation could result in late-remittance penalties being levied in error – but that “these late-remitting penalties can be cancelled once the CRA is provided additional information regarding the timing of the payments made to the non-resident.”

Neal Armstrong. Summary of 2021 Alberta CPA Roundtable under “Estates/ Trusts and Nonresident Withholding Tax” under s. 214(3)(f).