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[FN3:Paragraph (a) provides that a contribution to a trust means a transfer or loan (other than an arm’s length transfer) of property to a trust by a particular person or partnership — in our case Father.] ... Put differently, the issue is not whether the transfer causes a person or partnership to receive an interest in the trust — it is that a beneficiary’s existing or future interest in the trust motivates the transferor to make the transfer. ... Additional guidance on the TOSI rules can be found on the CRA website at: https: // www.canada.ca/en/revenue-agency/programs/about-canada-revenue-agency-cra/federal-government-budgets/income-sprinkling/guidance-split-income-rules-adults.html. ...

., R & D) in-house, then this nexus ratio would be equal to one. That ratio is then applied to the overall income from the IP asset, to determine the amount of income which is eligible to receive benefits under a preferential regime. ...

In the first scenario of entry into force on December 1, 2018, there would then be an entry into effect in Canada, with respect to withholding taxes, on January 1, 2019 – which, of course, assumes that there is a match with another jurisdiction where the instrument is in force by then. ...

The presenters were: Gord Parr, Director, Large Business Audit Division, International and Large Business Directorate, Compliance Programs Branch Andrew Kingissepp, Partner, Taxation, Osler, Hoskin & Harcourt LLP Certain questions that briefly introduced the topics (e.g. ...