Section 94.2

Subsection 94.2(1)

Administrative Policy

S5-F3-C1 - Taxation of a Roth IRA

Roth IRA of a resident generally is FAPI (absent a Treaty exemption)

1.6 The taxation in Canada of a Roth IRA that is a trust is fact specific....

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Subsection 94.2(2) - Deemed corporation

Administrative Policy

9 July 2015 External T.I. 2013-0475421E5 - Section 94.2

An exempt foreign trust (the "Trust") is deemed by s. 94.2(2) to be a non-resident corporation controlled by (and therefore a CFA of) a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 220 - Subsection 220(2.1) potential relief from penalties where insufficient data for computing FAPI 191
Tax Topics - Income Tax Act - Section 233.5 potential relief from penalties where insufficient data for computing FAPI 195
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.14) no stated accommodation for using proxy method where data unavailable 289

Subsection 94.2(3)

Articles

Michael N. Kandev, Matias Milet, "Foreign Trusts", 2017 Annual CTF Conference draft paper

Whether s. 104(13) inclusion test is satisfied in case of foreign trust (p. 21)

[S]ubsection 94.2(3) provides for a deduction in computing the...

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