Section 269

Administrative Policy

GST/HST Technical Information Bulletin B-068 "Bare Trusts" Amended 10 January 2005

transfer of registered title by (or to) bare trustee generally is for nil consideration

After discussing whether there is a bare trust, CRA stated:

[S]ections 268 and 269 of the Act provide that, for GST purposes, there will be a supply when any property, including the legal estate, is settled with a trustee or distributed to the beneficial owners, even if this is not a disposition for income tax purposes. Nevertheless, legal title without the equitable interest would normally have little or no monetary value. The settling of the legal title in a bare trust and the transfer of the title to the beneficial owner would normally have no GST implications.

Guide for Providers of Financial Services under "Distribution by Trust"

General discussion.