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Ruling

2002 Ruling 2002-0168463 - REIT with seconded employees

The Trust will not make any payment directly or indirectly to the Underwriters or to the Settlor to reimburse them for the $XXXXXXXXXX contribution. The property held in the Sub Trust will not revert to the Settlor nor will the Settlor have any control or influence over the affairs of the Sub Trust. 12. ...
Ruling

2015 Ruling 2015-0574901R3 - Qualifying environmental trust

ACo L.P. is a “Canadian partnership” for the purposes of the Act; “Agreement” means the trust agreement entered into by ACo on behalf of ACo L.P. and XXXXXXXXXX approved by the NEB on XXXXXXXXXX; “Beneficiary” or “Beneficiaries” is defined in the Agreement to mean the Person or Persons, including the Company, acting on its own capacity or acting on behalf of a partnership, having Reclamation Obligations in respect of the Site; “Company” means the person holding the regulatory authorization(s) for the time being to operate the Pipeline whether on its own behalf or on behalf of one or more Persons; “Contribution” means the initial contribution of Property made by ACo to settle the Fund and all subsequent contributions of Abandonment Charges or other amounts made to the Trust by the Company or by any other person or entity from time to time; “Deactivation” has the meaning set out in the definition of “deactivate” in the National Energy Board Onshore Pipeline Regulations (Canada); “Decommissioning” has the meaning set out in the definition of “decommission” in the National Energy Board Onshore Pipeline Regulations (Canada); “Fund” means (i) all Contributions made to the Trust from time to time, (ii) all interest, returns, gains, dividends, distributions or other proceeds of any investment of any such amounts and of any such proceeds from time to time, and (iii) all other amounts and Property held from time to time by the Trustee, of any nature or kind; “NEB” means the National Energy Board, established pursuant to the NEB Act, or any successor administrative body having authority to regulate the Company in respect of the operation and abandonment of the Pipeline; “NEB Act” means the National Energy Board Act (Canada), R.S.C. 1985, c N-7, as amended; “NEB Decision” means an applicable decision, order, direction or other determination of the NEB relating to Abandonment, Reclamation Obligations or the Trust; “Orphan Pipeline Fund” means a not-for-profit corporation that will be established pursuant to a statute of the Parliament of Canada and will maintain funds for the purpose of funding the reclamation of abandoned pipelines in Canada, consistent with the NEB’s Reasons for Decision MH-001-2013; “Person” includes a partnership; “Pipeline” means XXXXXXXXXX; “Property” means all tangible and intangible assets and rights of any nature or type and includes without limitation cash and securities within the meaning ascribed to that term for purposes of the Securities Act (XXXXXXXXXX); “Qualified Investments” means those investments that from time to time are qualified investments for a qualifying environmental trust and that are not encompassed within the definition of “prohibited investment” in subsection 211.6(1); and which as of XXXXXXXXXX include only those types of property described in paragraphs (a), (b), (c), (c.1), (d) and (f) of the definitions of “qualified investment” in section 204; and “Qualified Investment” means any one of them; “qualifying environmental trust” or “QET” has the meaning assigned to this term by subsection 211.6(1); “Reclamation Obligations” means (i) the duty to carry out the physical Abandonment, Decommissioning or Deactivation of the Pipeline, including costs incurred to satisfy any conditions imposed by the NEB in any order or direction approving the Decommissioning or Deactivation of the Pipeline or granting leave to Abandon the Pipeline; (ii) the duty to develop an Abandonment plan, and to prepare an application for leave to Abandon or for approval of the Deactivation or Decommissioning of the Pipeline; and (iii) the duty to carry out post-abandonment monitoring and remediation of the Site, where post-abandonment refers to the period of time after a Company has satisfied the conditions of an order or direction issued by the NEB granting leave to Abandon, and all costs incurred and consequent thereon; “Site” means the location or locations in Canada used for the operation of the Pipeline; “Statement of Investment Policies and Procedures” or “SIPP” means the Statement of Investment Policies and Procedures adopted by ACo, depicted by the SIPP for affiliates of XXXXXXXXXX including ACo; “Trust” means the discretionary trust settled under the Agreement for the purpose of reclamation in favour of the one or several Beneficiaries that have Reclamation Obligations with regard to the Site, and also of the Orphan Pipeline Fund, and which is called the “XXXXXXXXXX”. ...
Ruling

2003 Ruling 2003-0050303 - AT-RISK BENEFIT AND ENVIRONMENTAL TRUST

Such money contribution is property as described in paragraph (a) of the definition of "qualified investments" in section 204 of the Act. 37. ...
Old website (cra-arc.gc.ca)

T3 Trust Guide - 2016

Contribution of property – generally refers to a transfer or loan of property, other than an “arm’s length transfer” (as defined in subsection 94(1)) to a non-resident trust by a person or partnership. ... Question 9 – See Contribution of property in the definitions section. ... Index Index of items and their income tax act references Topic Income Tax Act reference Actual amount of dividends from taxable Canadian corporations 82(1), 260(5) Adjusted cost base 53, 54 Allocations and designations 104(6), (13), (19), (20), (21), (22), (22.1), (27), (27.1), (29) Allowable business investment losses (ABIL) 38(c), 39(1)(c), 39(10), 50(1) Allowable federal political contribution tax credit 127(3) Alter ego trust 104(4)(a), 248(1) Amount resulting in cost base adjustment 53(1), (2) Amending, cancelling, adding, or replacing trust related information slips Arm's length transaction 251(1) Bonds British Columbia mining exploration tax credit Canadian cultural property 39(1)(a)(i.1), 118.1(10) Capital dispositions Capital gains 3, 38, 38.1, 39, 40, 138.1(3) Capital gains deduction 110.6(12) Capital gains refund 132 Carrying charges and interest expenses 20(1)(c), (bb), 20(2.1) Clearance certificate 159(2), (3) Communal organization 143 Completing the NR4 return Crown royalties Death benefits 104(28), 248(1) Deemed disposition 104(4), (5), (5.1), (5.2) Deemed resident trust 94(1), 94(3) Definitions Administrator Allocate, allocation Arm's length transaction Beneficiary Common-law partner Contribution of property Deemed disposition Designate, designation Distribute, distribution Excluded property Executor Exempt property Gift Liquidator Preferred beneficiary Principal residence Settlor Spouse Testator Trust Trustee Vested interest Will Designated beneficiary 210 Distributing the T3 slip Distribution of property to beneficiaries 104(5.3), 107(2), (2.1), (2.2), (4) Dividend income 82(1), 104(19) Dividends, gross-up 82(1)(b) Dividends, non-taxable received by a trust 53(2), 83(1), (2), 104(20) Donations and gifts 104(6), 118.1, 143(3.1) Election- 164(6) Election- 164(6.1) Election to defer payment of tax (Form T2223) 159(6.1), (7) Elections (late or amended) 220(3.2), Reg. 600 Eligible beneficiary Employee benefit plan 6(1)(g), 6(10), 12(1)(n.1), 18(1)(o), 32.1, 104(6), 248(1) Employee life and health trust 144.1(2) Employee trust 6(1)(h), 104(6), 248(1) Exemption from Form T1055 deemed dispositions 108(1) Farming and fishing losses 31, 111(1)(c), (d), 111(8) Farming income Federal dividend tax credit 121 Federal foreign tax credit 20(11), (12), 126 Federal income tax Federal political contribution tax credit 127(3) Final return Fishing income Foreign investment income Foreign non-business income tax paid 104(22.1), 126(1)(a) Foreign property – Reporting requirements Graduated rate estate (GRE) 248(1) Gross-up amount of dividends 82(1)(b) How to file the T3 slip and summary How to register a formal dispute 165(1) Identification and other required information Income paid or payable to non-resident beneficiaries 104(13), 212(1)(c) Income paid or payable to resident beneficiaries Income to be taxed in the trust Insurance segregated fund trust 138.1 Inter vivos trust 108(1), 122 Interest 161, 164(3), 248(11), Reg. 4300, 4301, 4302 International financial reporting standards Investment income Investment tax credit (ITC) 13(7.1), 37(1), 127(5), (12.3) Investment tax credit – designated 127(7) Joint spousal or common-law partner trust 104(4)(a), 248(1) Listed personal property 41, 54 Loss carryback, request Lump-sum payments ITAR 40(1), (5), (7) Lump-sum pension income 60(j), 104(27), (27.1) Manitoba Mineral Exploration Tax Credit Master trust 149(1)(o.4), Reg. 4802(1.1) Minimum tax 120.2, 127.5 to 127.55 Mutual fund trust 132(6), (6.1), (7), Reg. 4801, 4803 Mutual fund units and other shares 248(1) My Account Net capital losses of other years 3, 38, 39, 104(21), 111(1)(b), 111(8) Newfoundland and Labrador research and development tax credit Non-capital losses of other years 111(1)(a), 111(8) Non-profit organization 149(1)(l), 149(5), (12) Non-resident beneficiary Non-resident tax payable 212(1)(c) Non-resident trusts Non-resident withholding tax- Part XIII 212 Other credits Other income Other investment income Other required information Outlays and expenses 40(1) Part XII.2 tax 210 to 210.3 Part XII.2 tax credit 120(2) Part XIII tax 212 to 217 Penalties 162(1), (2), (7), 163(1), 238(1), Reg. 209 Pension income (benefits) 56(1)(a)(i), 147(10) Personal trust 248(1) Personal-use property 40(2)(g)(iii), 46, 54 Political contribution tax credit (federal) 127(3) Preferred beneficiary election 104(12), (14), (14.01), (14.02), (15), 108(1), Reg. 2800 Principal residence 40(2)(c), (4), 54, 107(2.01) Proceeds of disposition 54, 107(2), (4) Property acquired before 1972 40(1), ITAR 24, 26(3), 26(7) Qualified Disability Trust (QDT) 122(2) Qualified farm or fishing property 110.6(1), (14), 248(1) Qualified small business corporation shares 110.6(1), (14), 248(1) Qualifying environmental trust 211.6(1) Qualifying pension income 104(27), 118(7) Real estate and depreciable property 13(21), ITAR 20(1) Reassessments 152(3.1), (4), (4.1), (4.2), 244(14), (15) Recipient identification number 162(5), (6), 237, 239(2.3) Refundable Part XII.2 tax credit Refundable Quebec abatement 120(2) Registered disability savings plan (RDSP) trust Registered retirement savings plans (RRSP) Rental income Reserves on dispositions of capital property 40(1)(a)(iii) Residence of trust Retirement compensation arrangement (RCA) 248(1) Royalties 12(1)(o) RRSP, RRIF, or RESP trusts Salary deferral arrangement 6(1)(a), (i), 6(11), (12), 248(1) Schedule 1 – Dispositions of Capital Property Schedule 8 – Investment Income, Carrying Charges, and Gross-up Amount of Dividends Retained by the Trust Schedule 9 – Income Allocations and Designations to Beneficiaries 104(13), (14), 108(1), 212(1)(c), Reg. 2800 Schedule 10 – Part XII.2 Tax and Part XIII Non-Resident Withholding Tax Schedule 11 – Federal Income Tax Schedule 12 – Minimum Tax Security options deduction 164(6.1) Service complaints Specified income 210.2(2) Specified investment flow-through (SIFT) trust Specified trust 108(1) Split income 120.4 Spousal or common-law partner trust 104(4)(a), 108(1) Summary of deemed dispositions (Form T1055) 104(4), (5), (5.1), (5.2) Surtax on income not subject to provincial or territorial tax 120(1) T3 slip (completing and distributing) Tax adjustments – Lump sum payments ITAR 40 Tax paid by instalments Taxable capital gains 3, 38, 39, 40(1), 104(21), (21.3) Taxable capital gains eligible for deduction 104(21), (21.1), (21.2), 110.6 Tax-free savings account (TFSA) trust 146.2(5), 248(1) Taxpayer Bill of Rights Tax year 104(23), 248, 249(1)(b) Testamentary trust 73, 108(1), 248(8), (9.1) Total capital losses transferred under 164(6) Total income allocations and designations to beneficiaries Transfer and loans of property 56(4.1) to (4.3), 74.1(1), (2), 74.2, 74.3, 74.5, 248(25), 251, 252 Transfer of trust property to another trust 104(5.8) Trustee fees 9(1), 20(1)(bb) Types of trusts Unit trust 108(2) Upkeep, maintenance, taxes – Beneficiary 105(2) Value of other benefits to a beneficiary 105(1) Yukon research and development tax credit Date modified: 2017-03-02 ...
Scraped CRA Website

T3 Trust Guide - 2016

Contribution of property – generally refers to a transfer or loan of property, other than an “arm’s length transfer” (as defined in subsection 94(1)) to a non-resident trust by a person or partnership. ... Question 9 – See Contribution of property in the definitions section. ... Index Index of items and their income tax act references Topic Income Tax Act reference Actual amount of dividends from taxable Canadian corporations 82(1), 260(5) Adjusted cost base 53, 54 Allocations and designations 104(6), (13), (19), (20), (21), (22), (22.1), (27), (27.1), (29) Allowable business investment losses (ABIL) 38(c), 39(1)(c), 39(10), 50(1) Allowable federal political contribution tax credit 127(3) Alter ego trust 104(4)(a), 248(1) Amount resulting in cost base adjustment 53(1), (2) Amending, cancelling, adding, or replacing trust related information slips Arm's length transaction 251(1) Bonds British Columbia mining exploration tax credit Canadian cultural property 39(1)(a)(i.1), 118.1(10) Capital dispositions Capital gains 3, 38, 38.1, 39, 40, 138.1(3) Capital gains deduction 110.6(12) Capital gains refund 132 Carrying charges and interest expenses 20(1)(c), (bb), 20(2.1) Clearance certificate 159(2), (3) Communal organization 143 Completing the NR4 return Crown royalties Death benefits 104(28), 248(1) Deemed disposition 104(4), (5), (5.1), (5.2) Deemed resident trust 94(1), 94(3) Definitions Administrator Allocate, allocation Arm's length transaction Beneficiary Common-law partner Contribution of property Deemed disposition Designate, designation Distribute, distribution Excluded property Executor Exempt property Gift Liquidator Preferred beneficiary Principal residence Settlor Spouse Testator Trust Trustee Vested interest Will Designated beneficiary 210 Distributing the T3 slip Distribution of property to beneficiaries 104(5.3), 107(2), (2.1), (2.2), (4) Dividend income 82(1), 104(19) Dividends, gross-up 82(1)(b) Dividends, non-taxable received by a trust 53(2), 83(1), (2), 104(20) Donations and gifts 104(6), 118.1, 143(3.1) Election- 164(6) Election- 164(6.1) Election to defer payment of tax (Form T2223) 159(6.1), (7) Elections (late or amended) 220(3.2), Reg. 600 Eligible beneficiary Employee benefit plan 6(1)(g), 6(10), 12(1)(n.1), 18(1)(o), 32.1, 104(6), 248(1) Employee life and health trust 144.1(2) Employee trust 6(1)(h), 104(6), 248(1) Exemption from Form T1055 deemed dispositions 108(1) Farming and fishing losses 31, 111(1)(c), (d), 111(8) Farming income Federal dividend tax credit 121 Federal foreign tax credit 20(11), (12), 126 Federal income tax Federal political contribution tax credit 127(3) Final return Fishing income Foreign investment income Foreign non-business income tax paid 104(22.1), 126(1)(a) Foreign property – Reporting requirements Graduated rate estate (GRE) 248(1) Gross-up amount of dividends 82(1)(b) How to file the T3 slip and summary How to register a formal dispute 165(1) Identification and other required information Income paid or payable to non-resident beneficiaries 104(13), 212(1)(c) Income paid or payable to resident beneficiaries Income to be taxed in the trust Insurance segregated fund trust 138.1 Inter vivos trust 108(1), 122 Interest 161, 164(3), 248(11), Reg. 4300, 4301, 4302 International financial reporting standards Investment income Investment tax credit (ITC) 13(7.1), 37(1), 127(5), (12.3) Investment tax credit – designated 127(7) Joint spousal or common-law partner trust 104(4)(a), 248(1) Listed personal property 41, 54 Loss carryback, request Lump-sum payments ITAR 40(1), (5), (7) Lump-sum pension income 60(j), 104(27), (27.1) Manitoba Mineral Exploration Tax Credit Master trust 149(1)(o.4), Reg. 4802(1.1) Minimum tax 120.2, 127.5 to 127.55 Mutual fund trust 132(6), (6.1), (7), Reg. 4801, 4803 Mutual fund units and other shares 248(1) My Account Net capital losses of other years 3, 38, 39, 104(21), 111(1)(b), 111(8) Newfoundland and Labrador research and development tax credit Non-capital losses of other years 111(1)(a), 111(8) Non-profit organization 149(1)(l), 149(5), (12) Non-resident beneficiary Non-resident tax payable 212(1)(c) Non-resident trusts Non-resident withholding tax- Part XIII 212 Other credits Other income Other investment income Other required information Outlays and expenses 40(1) Part XII.2 tax 210 to 210.3 Part XII.2 tax credit 120(2) Part XIII tax 212 to 217 Penalties 162(1), (2), (7), 163(1), 238(1), Reg. 209 Pension income (benefits) 56(1)(a)(i), 147(10) Personal trust 248(1) Personal-use property 40(2)(g)(iii), 46, 54 Political contribution tax credit (federal) 127(3) Preferred beneficiary election 104(12), (14), (14.01), (14.02), (15), 108(1), Reg. 2800 Principal residence 40(2)(c), (4), 54, 107(2.01) Proceeds of disposition 54, 107(2), (4) Property acquired before 1972 40(1), ITAR 24, 26(3), 26(7) Qualified Disability Trust (QDT) 122(2) Qualified farm or fishing property 110.6(1), (14), 248(1) Qualified small business corporation shares 110.6(1), (14), 248(1) Qualifying environmental trust 211.6(1) Qualifying pension income 104(27), 118(7) Real estate and depreciable property 13(21), ITAR 20(1) Reassessments 152(3.1), (4), (4.1), (4.2), 244(14), (15) Recipient identification number 162(5), (6), 237, 239(2.3) Refundable Part XII.2 tax credit Refundable Quebec abatement 120(2) Registered disability savings plan (RDSP) trust Registered retirement savings plans (RRSP) Rental income Reserves on dispositions of capital property 40(1)(a)(iii) Residence of trust Retirement compensation arrangement (RCA) 248(1) Royalties 12(1)(o) RRSP, RRIF, or RESP trusts Salary deferral arrangement 6(1)(a), (i), 6(11), (12), 248(1) Schedule 1 – Dispositions of Capital Property Schedule 8 – Investment Income, Carrying Charges, and Gross-up Amount of Dividends Retained by the Trust Schedule 9 – Income Allocations and Designations to Beneficiaries 104(13), (14), 108(1), 212(1)(c), Reg. 2800 Schedule 10 – Part XII.2 Tax and Part XIII Non-Resident Withholding Tax Schedule 11 – Federal Income Tax Schedule 12 – Minimum Tax Security options deduction 164(6.1) Service complaints Specified income 210.2(2) Specified investment flow-through (SIFT) trust Specified trust 108(1) Split income 120.4 Spousal or common-law partner trust 104(4)(a), 108(1) Summary of deemed dispositions (Form T1055) 104(4), (5), (5.1), (5.2) Surtax on income not subject to provincial or territorial tax 120(1) T3 slip (completing and distributing) Tax adjustments – Lump sum payments ITAR 40 Tax paid by instalments Taxable capital gains 3, 38, 39, 40(1), 104(21), (21.3) Taxable capital gains eligible for deduction 104(21), (21.1), (21.2), 110.6 Tax-free savings account (TFSA) trust 146.2(5), 248(1) Taxpayer Bill of Rights Tax year 104(23), 248, 249(1)(b) Testamentary trust 73, 108(1), 248(8), (9.1) Total capital losses transferred under 164(6) Total income allocations and designations to beneficiaries Transfer and loans of property 56(4.1) to (4.3), 74.1(1), (2), 74.2, 74.3, 74.5, 248(25), 251, 252 Transfer of trust property to another trust 104(5.8) Trustee fees 9(1), 20(1)(bb) Types of trusts Unit trust 108(2) Upkeep, maintenance, taxes – Beneficiary 105(2) Value of other benefits to a beneficiary 105(1) Yukon research and development tax credit Report a problem or mistake on this page Privacy statement The information you provide through this survey is collected under the authority of the Department of Employment and Social Development Act (DESDA) for the purpose of measuring the performance of Canada.ca and continually improving the website. ...
Current CRA website

T3 Trust Guide – 2024

Common-law partner – This refers to a person who is not your spouse with whom you are living in a conjugal relationship, and to whom at least one of the following situations applies: a) This person has been living with you in such a relationship for at least 12 continuous months Note In this definition, 12 continuous months includes any period you were separated for less than 90 days because of a breakdown in the relationship. b) This person is the parent of your child by birth or adoption c) This person has custody and control of your child (or had custody and control immediately before the child turned 19 years of age) and your child is wholly dependent on that person for support Contribution of property – This generally refers to a transfer or loan of property, other than an arm’s length transfer [as defined in subsection 94(1)] to a non-resident trust by a person or partnership. ... Question 9 – See Contribution of property in the definitions section. ... Index Index of items and their income tax act references Topic Income Tax Act reference Actual amount of dividends from taxable Canadian corporations 82(1), 260(5) Adjusted cost base 53, 54 Allocations and designations 104(6), (13), (19), (20), (21), (22), (22.1), (27), (27.1), (29) Allowable business investment losses (ABIL) 38(c), 39(1)(c), 39(10), 50(1) Allowable federal political contribution tax credit 127(3) Alter ego trust 104(4)(a), 248(1) Amount resulting in cost base adjustment 53(1), (2) Amending, cancelling, adding, or replacing trust related information slips Arm's length transaction 251(1) Bonds British Columbia clean buildings tax credit British Columbia mining exploration tax credit Canadian cultural property 39(1)(a)(i.1), 118.1(10) Capital dispositions Capital gains 3, 38, 38.1, 39, 40, 138.1(3) Capital gains deduction 110.6(12) Capital gains refund 132 Carrying charges and interest expenses 20(1)(c), (bb), 20(2.1) Clearance certificate 159(2), (3) Communal organization 143 Completing the NR4 return Crown royalties Death benefits 104(28), 248(1) Deemed disposition 104(4), (5), (5.1), (5.2) Deemed resident trust 94(1), 94(3) Definitions Administrator Allocate, allocation Arm's length transaction Beneficiary Controlling person Common-law partner Contribution of property Deemed disposition Designate, designation Distribute, distribution Executor Exempt property Gift Liquidator Preferred beneficiary Principal residence Settlor Spouse Testator Trust Trustee Vested interest Will Designated beneficiary 210 Distributing the T3 slip Distribution of property to beneficiaries 104(5.3), 107(2), (2.1), (2.2), (4) Dividend income 82(1), 104(19) Dividends, gross-up 82(1)(b) Dividends, non-taxable received by a trust 53(2), 83(1), (2), 104(20) Donations and gifts 104(6), 118.1, 143(3.1) Election- 164(6) Election- 164(6.1) Election to defer payment of tax (Form T2223) 159(6.1), (7) Elections (late or amended) 220(3.2), Reg. 600 Eligible beneficiary Employee benefit plan 6(1)(g), 6(10), 12(1)(n.1), 18(1)(o), 32.1, 104(6), 248(1) Employee life and health trust 144.1(2) Employee ownership trust 248(1) Employee trust 6(1)(h), 104(6), 248(1) Exemption from Form T1055 deemed dispositions 108(1) Farming and fishing losses 31, 111(1)(c), (d), 111(8) Farming income Federal dividend tax credit 121 Federal foreign tax credit 20(11), (12), 126 Federal income tax Federal political contribution tax credit 127(3) Final return Fishing income Foreign investment income Foreign non-business income tax paid 104(22.1), 126(1)(a) Foreign property – Reporting requirements Graduated rate estate (GRE) 248(1) Gross-up amount of dividends 82(1)(b) How to file the T3 slip and summary How to register a formal dispute 165(1) Identification and other required information Income paid or payable to non-resident beneficiaries 104(13), 212(1)(c) Income paid or payable to resident beneficiaries Income to be taxed in the trust Insurance segregated fund trust 138.1 Inter vivos trust 108(1), 122 Interest 161, 164(3), 248(11), Reg. 4300, 4301, 4302 International financial reporting standards Investment income Investment tax credit (ITC) 13(7.1), 37(1), 127(5), (12.3) Investment tax credit – designated 127(7) Joint spousal or common-law partner trust 104(4)(a), 248(1) Listed personal property 41, 54 Loss carry-back, request Loss restriction event 251.2(2) Lump-sum pension income 60(j), 104(27), (27.1) Master trust 149(1)(o.4), Reg. 4802(1.1) Minimum tax 120.2, 127.5 to 127.55 Mutual fund trust 132(6), (6.1), (7), Reg. 4801, 4803 Mutual fund units and other shares 248(1) My Account Net capital losses of other years 3, 38, 39, 104(21), 111(1)(b), 111(8) Newfoundland and Labrador research and development tax credit Non-capital losses of other years 111(1)(a), 111(8) Non-profit organization 149(1)(l), 149(5), (12) Non-resident beneficiary Non-resident tax payable 212(1)(c) Non-resident trusts Non-resident withholding tax- Part XIII 212 Other credits Other income Other investment income Other required information Outlays and expenses 40(1) Part XII.2 tax 210 to 210.3 Part XII.2 tax credit 210.2(3), (4) Part XIII tax 212 to 217 Penalties 162(1), (2), (7), (7.01), 163(1), 163.2(4), 238(1) Pension income (benefits) 56(1)(a)(i), 147(10) Personal trust 248(1) Personal-use property 40(2)(g)(iii), 46, 54 Political contribution tax credit (federal) 127(3) Preferred beneficiary election 104(12), (14), (14.01), (14.02), (15), 108(1), Reg. 2800 Principal residence 40(2)(c), (4), 54, 107(2.01) Proceeds of disposition 54, 107(2), (4) Property acquired before 1972 40(1), ITAR 24, 26(3), 26(7) Qualified disability trust (QDT) 122(2) Qualified farm or fishing property 110.6(1), (14), 248(1) Qualified small business corporation shares 110.6(1), (14), 248(1) Qualifying environmental trust 211.6(1) Qualifying pension income 104(27), 118(7) Real estate and depreciable property 13(21), ITAR 20(1) Reassessments 152(3.1), (4), (4.1), (4.2), 244(14), (15) Recipient identification number 162(5), (6), 237, 239(2.3) Refundable Part XII.2 tax credit Refundable Quebec abatement 120(2) Registered disability savings plan (RDSP) trust Registered retirement savings plans (RRSP) Rental income Reserves on dispositions of capital property 40(1)(a)(iii) Residence of trust Retirement compensation arrangement (RCA) 248(1) Royalties 12(1)(o) RRSP, RRIF, or RESP trusts Salary deferral arrangement 6(1)(a), (i), 6(11), (12), 248(1) Schedule 1 – Dispositions of Capital Property Schedule 8 – Investment Income, Carrying Charges, and Gross-up Amount of Dividends Retained by the Trust Schedule 9 – Income Allocations and Designations to Beneficiaries 104(13), (14), 108(1), 212(1)(c), Reg. 2800 Schedule 10 – Part XII.2 Tax and Part XIII Non-Resident Withholding Tax Schedule 11 – Federal Income Tax Schedule 12 – Minimum Tax Schedule 15 – Beneficial Ownership Information of a Trust Security options deduction 164(6.1) Service complaints Specified income 210.2(2) Specified investment flow-through (SIFT) trust Specified trust 108(1) Split income 120.4 Spousal or common-law partner trust 104(4)(a), 108(1) Summary of deemed dispositions (Form T1055) 104(4), (5), (5.1), (5.2) Surtax on income not subject to provincial or territorial tax 120(1) T3 slip (completing and distributing) Tax paid by instalments Taxable capital gains 3, 38, 39, 40(1), 104(21), (21.3) Taxable capital gains eligible for deduction 104(21), (21.1), (21.2), 110.6 Tax-free savings account (TFSA) trust 146.2(5), 248(1) Taxpayer Bill of Rights Tax year 104(23), 248, 249(1)(b) Testamentary trust 73, 108(1), 248(8), (9.1) Total capital losses transferred under 164(6) Total income allocations and designations to beneficiaries Transfer and loans of property 56(4.1) to (4.3), 74.1(1), (2), 74.2, 74.3, 74.5, 248(25), 251, 252 Transfer of trust property to another trust 104(5.8) Trustee fees 9(1), 20(1)(bb) Types of trusts Unit trust 108(2) Upkeep, maintenance, taxes – Beneficiary 105(2) Value of other benefits to a beneficiary Yukon business carbon price rebate Yukon mining carbon price rebate 105(1) Yukon research and development tax credit Page details Date modified: 2025-03-03 ...
Current CRA website

T3 Trust Guide – 2020

Contribution of property – generally refers to a transfer or loan of property, other than an “arm’s length transfer” (as defined in subsection 94(1)) to a non-resident trust by a person or partnership. ... Question 9 – See Contribution of property in the definitions section. ... Index Index of items and their income tax act references Topic Income Tax Act reference Actual amount of dividends from taxable Canadian corporations 82(1), 260(5) Adjusted cost base 53, 54 Allocations and designations 104(6), (13), (19), (20), (21), (22), (22.1), (27), (27.1), (29) Allowable business investment losses (ABIL) 38(c), 39(1)(c), 39(10), 50(1) Allowable federal political contribution tax credit 127(3) Alter ego trust 104(4)(a), 248(1) Amount resulting in cost base adjustment 53(1), (2) Amending, cancelling, adding, or replacing trust related information slips Arm's length transaction 251(1) Bonds British Columbia mining exploration tax credit Canadian cultural property 39(1)(a)(i.1), 118.1(10) Capital dispositions Capital gains 3, 38, 38.1, 39, 40, 138.1(3) Capital gains deduction 110.6(12) Capital gains refund 132 Carrying charges and interest expenses 20(1)(c), (bb), 20(2.1) Clearance certificate 159(2), (3) Communal organization 143 Completing the NR4 return Crown royalties Death benefits 104(28), 248(1) Deemed disposition 104(4), (5), (5.1), (5.2) Deemed resident trust 94(1), 94(3) Definitions Administrator Allocate, allocation Arm's length transaction Beneficiary Common-law partner Contribution of property Deemed disposition Designate, designation Distribute, distribution Executor Exempt property Gift Liquidator Preferred beneficiary Principal residence Settlor Spouse Testator Trust Trustee Vested interest Will Designated beneficiary 210 Distributing the T3 slip Distribution of property to beneficiaries 104(5.3), 107(2), (2.1), (2.2), (4) Dividend income 82(1), 104(19) Dividends, gross-up 82(1)(b) Dividends, non-taxable received by a trust 53(2), 83(1), (2), 104(20) Donations and gifts 104(6), 118.1, 143(3.1) Election- 164(6) Election- 164(6.1) Election to defer payment of tax (Form T2223) 159(6.1), (7) Elections (late or amended) 220(3.2), Reg. 600 Eligible beneficiary Employee benefit plan 6(1)(g), 6(10), 12(1)(n.1), 18(1)(o), 32.1, 104(6), 248(1) Employee life and health trust 144.1(2) Employee trust 6(1)(h), 104(6), 248(1) Exemption from Form T1055 deemed dispositions 108(1) Farming and fishing losses 31, 111(1)(c), (d), 111(8) Farming income Federal dividend tax credit 121 Federal foreign tax credit 20(11), (12), 126 Federal income tax Federal political contribution tax credit 127(3) Final return Fishing income Foreign investment income Foreign non-business income tax paid 104(22.1), 126(1)(a) Foreign property – Reporting requirements Graduated rate estate (GRE) 248(1) Gross-up amount of dividends 82(1)(b) How to file the T3 slip and summary How to register a formal dispute 165(1) Identification and other required information Income paid or payable to non-resident beneficiaries 104(13), 212(1)(c) Income paid or payable to resident beneficiaries Income to be taxed in the trust Insurance segregated fund trust 138.1 Inter vivos trust 108(1), 122 Interest 161, 164(3), 248(11), Reg. 4300, 4301, 4302 International financial reporting standards Investment income Investment tax credit (ITC) 13(7.1), 37(1), 127(5), (12.3) Investment tax credit – designated 127(7) Joint spousal or common-law partner trust 104(4)(a), 248(1) Listed personal property 41, 54 Loss carryback, request Loss restriction event 251.2(2) Lump-sum pension income 60(j), 104(27), (27.1) Master trust 149(1)(o.4), Reg. 4802(1.1) Minimum tax 120.2, 127.5 to 127.55 Mutual fund trust 132(6), (6.1), (7), Reg. 4801, 4803 Mutual fund units and other shares 248(1) My Account Net capital losses of other years 3, 38, 39, 104(21), 111(1)(b), 111(8) Newfoundland and Labrador research and development tax credit Non-capital losses of other years 111(1)(a), 111(8) Non-profit organization 149(1)(l), 149(5), (12) Non-resident beneficiary Non-resident tax payable 212(1)(c) Non-resident trusts Non-resident withholding tax- Part XIII 212 Other credits Other income Other investment income Other required information Outlays and expenses 40(1) Part XII.2 tax 210 to 210.3 Part XII.2 tax credit 210.2(3), (4) Part XIII tax 212 to 217 Penalties 162(1), (2), (7), (7.01), 163(1), 163.2(4), 238(1) Pension income (benefits) 56(1)(a)(i), 147(10) Personal trust 248(1) Personal-use property 40(2)(g)(iii), 46, 54 Political contribution tax credit (federal) 127(3) Preferred beneficiary election 104(12), (14), (14.01), (14.02), (15), 108(1), Reg. 2800 Principal residence 40(2)(c), (4), 54, 107(2.01) Proceeds of disposition 54, 107(2), (4) Property acquired before 1972 40(1), ITAR 24, 26(3), 26(7) Qualified Disability Trust (QDT) 122(2) Qualified farm or fishing property 110.6(1), (14), 248(1) Qualified small business corporation shares 110.6(1), (14), 248(1) Qualifying environmental trust 211.6(1) Qualifying pension income 104(27), 118(7) Real estate and depreciable property 13(21), ITAR 20(1) Reassessments 152(3.1), (4), (4.1), (4.2), 244(14), (15) Recipient identification number 162(5), (6), 237, 239(2.3) Refundable Part XII.2 tax credit Refundable Quebec abatement 120(2) Registered disability savings plan (RDSP) trust Registered retirement savings plans (RRSP) Rental income Reserves on dispositions of capital property 40(1)(a)(iii) Residence of trust Retirement compensation arrangement (RCA) 248(1) Royalties 12(1)(o) RRSP, RRIF, or RESP trusts Salary deferral arrangement 6(1)(a), (i), 6(11), (12), 248(1) Schedule 1 – Dispositions of Capital Property Schedule 8 – Investment Income, Carrying Charges, and Gross-up Amount of Dividends Retained by the Trust Schedule 9 – Income Allocations and Designations to Beneficiaries 104(13), (14), 108(1), 212(1)(c), Reg. 2800 Schedule 10 – Part XII.2 Tax and Part XIII Non-Resident Withholding Tax Schedule 11 – Federal Income Tax Schedule 12 – Minimum Tax Security options deduction 164(6.1) Service complaints Specified income 210.2(2) Specified investment flow-through (SIFT) trust Specified trust 108(1) Split income 120.4 Spousal or common-law partner trust 104(4)(a), 108(1) Summary of deemed dispositions (Form T1055) 104(4), (5), (5.1), (5.2) Surtax on income not subject to provincial or territorial tax 120(1) T3 slip (completing and distributing) Tax paid by instalments Taxable capital gains 3, 38, 39, 40(1), 104(21), (21.3) Taxable capital gains eligible for deduction 104(21), (21.1), (21.2), 110.6 Tax-free savings account (TFSA) trust 146.2(5), 248(1) Taxpayer Bill of Rights Tax year 104(23), 248, 249(1)(b) Testamentary trust 73, 108(1), 248(8), (9.1) Total capital losses transferred under 164(6) Total income allocations and designations to beneficiaries Transfer and loans of property 56(4.1) to (4.3), 74.1(1), (2), 74.2, 74.3, 74.5, 248(25), 251, 252 Transfer of trust property to another trust 104(5.8) Trustee fees 9(1), 20(1)(bb) Types of trusts Unit trust 108(2) Upkeep, maintenance, taxes – Beneficiary 105(2) Value of other benefits to a beneficiary 105(1) Yukon research and development tax credit Report a problem or mistake on this page Thank you for your help! ...
FCTD

Robert Julien Family Delaware Dynasty Trust v. Canada (National Revenue), 2007 FC 1071

Because the Trust received a contribution of property from a Canadian resident (Mrs. ...
FCA

Iberville Developments Limited v. Canada, 2020 FCA 115

. […]   Subdivision J — Partnerships and their Members Sous-section J — Les sociétés de personnes et leurs associés   Contribution of property to partnership Apport de biens dans une société de personnes 97(1) Where at any time after 1971 a partnership has acquired property from a taxpayer who was, immediately after that time, a member of the partnership, the partnership shall be deemed to have acquired the property at an amount equal to its fair market value at that time and the taxpayer shall be deemed to have disposed of the property for proceeds equal to that fair market value. 97(1) Lorsque, après 1971, une société de personnes a acquis des biens auprès d’un contribuable qui, immédiatement après le moment de l’acquisition, faisait partie de la société de personnes, cette dernière est réputée les avoir acquis à un prix égal à leur juste valeur marchande à ce moment et le contribuable est réputé en avoir disposé et en avoir tiré un produit égal à cette juste valeur marchande.   ...
Ruling

2005 Ruling 2004-0060241R3 - XXXXXXXXXX

In order for an inter vivos trust to be a personal trust, there must be no beneficial interest in the trust acquired for consideration payable to the trust or to any person who has made a contribution to the trust. 108(7) provides that, for purposes of the definition of personal trust in 248(1), if only one person makes a contribution of property to the trust, that person will be deemed to have acquired his or her beneficial interest in the trust for no consideration. ...

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