Audrey Gibeault, "Unexpected Application of Part XII.2 Tax to a Canadian Personal Trust", Canadian Tax Focus, Vol. 3, No. 2, May 2013, p. 10, at 11.
Planning opportunities to deal with the emigration of a beneficiary and the resulting application of Part XII.2 tax to a trust appear to be quite...
Ashutosh Gupta, "Amendments to Part XII.2 - Addressing Complex Trust Ownership Structures", Taxation Law, Ontario Bar Association, Vol. XIII, No. 3, March 2003, p. 4.
9 February 2017 External T.I. 2016-0657531E5 - Deemed resident trust and "designated beneficiary"
Is a non-resident trust, which is deemed to be resident for various purposes under s. 94(3)(a), considered to be a “non-resident person” for...
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|Tax Topics - Income Tax Act - Section 94 - Subsection 94(3) - Paragraph 94(3)(a)||no application to Pt. XII.2||44|
Brian Kearl, Carl Deeprose, "Leaving Canada's New High Tax Rate Regime: Considerations, Tips and Traps", 2016 Conference Report (Canadian Tax Foundation),32:1-24
Conversion of trusts deemed disposition income into “designated income” for purposes of Part XII.2 (pp. 32:16-17)
If an emigrating...