Search - "Contribution of Property"

5 March 1991 External T.I. 9035565 F- Contribution of Property to Trust Unedited CRA Tags 107(2.1), 108(1) testamentary trust, 248(1) personal trust Dear Sirs: This is in reply to your letter of November 29, 1990 wherein you request a technical interpretation concerning a situation where 24(1) As indicated in Information Circular 70-6R2, we do not express opinions on specific proposed transactions other than as a reply to an advance income tax ruling.  ... A payment of cash to the estate to enable it to pay the liabilities will result in a contribution of property to the trust for the purpose of subparagraph 108(1)(ii) of the Act.  ...

If the advantage remains in the RRSP, such as the earning of bonus interest in the plan or a contribution of property into the RRSP, this would not contravene the aforementioned provision. ...

If the advantage remains in the RRSP, such as the earning of bonus interest in the plan or a contribution of property into the RRSP, this would not contravene the aforementioned provision. ...

Likewise, a retirement compensation arrangement (RCA") can only arise where a contribution of property is made by the employer to the "custodian".  ...

Any contribution of property to a RRIF by the annuitant is prohibited by paragraph 146.3(2)(f) of the Act. ...

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. ...

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). ...

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. ...