Administrative Policy
4 June 2024 STEP Roundtable Q. 11, 2024-1003491C6 - Foreign Tax Credit for US Estate Tax
A Canadian resident who was not a U.S. citizen was subject on death to U.S. estate tax on U.S. situs property, namely, US real property and...
Folio S6-F4-C1, "Testamentary Spouse or Common-law Partner Trusts," 3 February 2022
Application of Art. XXIX B of the Canada-U.S. Treaty for US residents to access s. 70(6) rollover re TCP
1.63 … [F]or the rollover treatment in...
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.
Treaty relief from residency requirement in 70(6) – but “will” requirement (p. 171)
Subsection 70(6) applies to a transfer to a taxpayers...