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Technical Interpretation - Internal summary
1 November 2016 Internal T.I. 2016-0663971I7 - 104(6)(b), whether amount became payable -- summary under Subsection 104(24)
1 November 2016 Internal T.I. 2016-0663971I7- 104(6)(b), whether amount became payable-- summary under Subsection 104(24) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(24) income that is paid to a minor beneficiary in contravention of the trust deed is non-deductible under s. 104(6) Although the trust indenture for a family trust specified that no “designated person” beneficiary could receive or otherwise obtain the use of any of the income or capital of the trust, amounts nonetheless were paid to the minor beneficiaries, and purportedly included in their income under s. 104(13). ...