Search - "Contribution of Property"

A contribution of property to a trust generally implies that the trust receives the property without any value being given to the contributor. ...

While with respect to the situation set out above it is arguable that the Canadian resident beneficiaries did not contribute property to the non-resident trust, subsection 94(1) does not require a contribution of property to the trust. ...

While with respect to the situation set out above it is arguable that the Canadian resident beneficiaries did not contribute property to the non-resident trust, subsection 94(1) does not require a contribution of property to the trust. ...

If a trust was created by the contribution of property thereto jointly by an individual and the individual's spouse and no other person, the trust would be considered to be created by both individuals for purposes of subsection 73(1.01). ...

Further, you are of the view that income left in a trust as an amount payable does not constitute an additional contribution of property to the trust for purposes of the definition of "testamentary trust" in paragraph 108(1)(i) of the Act. ...

Further, you are of the view that income left in a trust as an amount payable does not constitute an additional contribution of property to the trust for purposes of the definition of "testamentary trust" in paragraph 108(1)(i) of the Act. ...

REASONS: Contribution of property voluntarily made. September 10, 1998 XXXXXXXXXX Dear XXXXXXXXXX: The Honourable Herb Dhaliwal, Minister of National Revenue, has asked me to reply to your letter to the Honourable Paul Martin, Minister of Finance, regarding the XXXXXXXXXX. ...

7 November 2022 External T.I. 2022-0926091E5- Transfer of UK DB pension benefits to a UK SIPP Unedited CRA Tags 56(1)(a); 94(1) "contribution" Principal Issues: (1) In a described situation, whether the amount transferred from a UK DB pension plan to a UK SIPP has to be included in the member’s income under paragraph 56(1)(a) in the tax year of the transfer. (2) Whether the transfer constitutes a “contribution” of property (within the meaning of subsection 94(1)) by the member to the trust governed by the UK SIPP. ... In addition, you also asked for our views on whether the transfer would constitute a “contribution” of property (within the meaning of subsection 94(1)) by the member to the trust governed by the UK SIPP. ...

Consequently, if the payment of the operating expenses of the cottage by the spouse were considered to be a contribution of property to the trust, the trust would lose its status as a testamentary trust. ...

In your scenario, the issue becomes whether the election by the spouse not to receive the income of the trust results in a contribution of property by the surviving spouse that increases the capital of the trust. ...