Mark Brender, Marc Roy, "Canadian Tax Trap Arising from Cross-Border Gift Tax Planning", Tax Notes International, Vol. 111, 4 September 2023, p. 1217

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Plain overview of when s. 94 applies (p. 1217)

Except for limited exceptions regarding principally some commercial and charitable trusts, s. 94...

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Need in light of (b) of “contribution” that any subsequent gift of property, by a donee of a Canadian resident, to a non-resident trust,...

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Use of s. 94(16) election to avoid FTC mismatch for grantor trust (pp. 1219 1222)

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FTC mismatch as a result of application of s. 104(7.01) (p. 1220)

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Example of application of s. 94(2)(k) (p. 1219)

S. 94(2)(k) could, for example, apply if a Canadian resident asks or directs a nonresident to...

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Example of application of s. 94(2)(a) (p. 1219)

S. 94(2)(a) would apply, for instance, to a transfer of property to a corporation owned by a...

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