Section 105

Subsection 105(1) - Benefits under trust

Cases

Cooper v. The Queen, 88 DTC 6525, [1989] 1 CTC 66 (FCTD)

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - General Concepts - Illegality income tax consequences attaching to illegal loan 75
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) interest-free loan 102

See Also

Stevenson v. Wishart, [1987] BTC 283 (CA)

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Administrative Policy

1 November 2016 Internal T.I. 2016-0663971I7 - 104(6)(b), whether amount became payable

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Locations of other summaries Wordcount
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) 180
Tax Topics - General Concepts - Illegality distribution contrary to trust deed not considered to be payable 123
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) prohibited distribution from trust 74

16 June 2014 STEP Roundtable, 2014-0523061C6 - Trust audit issues

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10 July 2013 Internal T.I. 2013-0475501I7 F - Amounts returned to trustee/beneficiary

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) family trust income distributed to children but repaid as reimbursement to father for family expenses was income to him, not them 199
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24) distributions to children immediately paid to father 174
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) distributions to children immediately paid to father were deductible even though received by children as his agents 169
Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) payment of distributed family trust income by children to father did not engage s. 56(4) as it was only potential income to him 167

6 August 2013 External T.I. 2012-0469481E5 F - Benefit under trust

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) benefit on estate sale to beneficiary at under-value added to property's ACB 129
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) taxable benefit added to acb 129

12 December 2012 Internal T.I. 2012-0464411I7 - Indirect Benefit

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4 December 2012 External T.I. 2012-0470951E5 F - Technical News no. 11

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5 July 2012 Internal T.I. 2010-0388551I7 F - Fiducie - retour de sommes

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) s. 75(2) does not apply to an estate freeze as the corp does not own its treasury shares issued to the trust 154
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) capital gain distributed by family trust to children and purportedly lent by them to their parents (also beneficiaries) was instead included in the parents’ income under s. 104(13) 403
Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(6) Foisy test of mental element accepted 221

1999 Ruling 9911853 [DRIP produces taxable benefit]

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Income Tax Technical News, No. 11, September 30, 1997: "Taxable Benefit for Use of Personal-Use Property"

26 August 1997 Memorandum 970731

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9 January 1997 T.I. 963753

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31 March 1993 T.I. (Tax Window, No. 29, p. 23, ¶2459)

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19 June 1992 Interpretation 9218430 (January - February 1993 Access Letter, p. 25, ¶C104-038)

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91 C.R. - Q10

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90 C.R. - Q24

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89 C.R. - Q31

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88 C.R. - Q69

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87 C.R. - Q82

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85 C.R. - Q27

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80 C.R. - Q45

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Articles

Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016.

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(3) 374
Tax Topics - Income Tax Act - Section 251.1 - Subsection 251.1(4) - Paragraph 251.1(4)(d) 437
Tax Topics - Income Tax Act - Section 251.1 - Subsection 251.1(1) - Paragraph 251.1(1)(g) - Subparagraph 251.1(1)(g)(ii) 115
Tax Topics - Income Tax Act - Section 164 - Subsection 164(6) 141
Tax Topics - Income Tax Act - Section 112 - Subsection 112(3.2) 331
Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(1) 144
Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(3) - Paragraph 251.2(3)(b) 112
Tax Topics - Income Tax Act - Section 252.2 - Subsection 252.2(2) 115
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(i) 176
Tax Topics - Income Tax Act - Section 70 - Subsection 70(6) - Paragraph 70(6)(d.1) 161
Tax Topics - Income Tax Act - Section 70 - Subsection 70(6) 1201
Tax Topics - Treaties - Income Tax Conventions - Article 29B 239
Tax Topics - Income Tax Act - Section 248 - (2)-(41) 157
Tax Topics - Income Tax Act - Section 248 - Subsection 248(8) 199
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(4) - Paragraph 104(4)(a.2) 59
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(4) - Paragraph 104(4)(a.3) 38
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(6) 174
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) 164
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24) 163
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(18) 49
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(7.01) 66
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(19) 311
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) 125
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) 144
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) 379

Subsection 105(2)

Articles

Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Beneficiaries Resident in Canada", Chapter 4 of Canadian Taxation of Trusts (Canadian Tax Foundation), 2016.

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