Words and Phrases - "vested indefeasibly"
17 March 2003 External T.I. 2002-0130685 F - Limite inférieure - JVM Participation
After referring to the meaning of “vested indefeasibly” discussed in IT-449R, CCRA stated:
Therefore, where the rights of the beneficiaries in...
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| Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(4) | purpose of s. 107.4(4) | 176 |
Folio S6-F4-C1, "Testamentary Spouse or Common-law Partner Trusts," 3 February 2022
1.2-1.3 Indefeasible vesting requirement. The capital property distributed to the spouse trust etc. must vest indefeasibly in it within 36 months...
15 June 2021 STEP Roundtable Q. 6, 2021-0883021C6 - Vested Indefeasibly
(a) What is required for all interests in a trust to have vested indefeasibly; and
(b) how is this disclosed on the trust return?
(a) CRA noted...
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| Tax Topics - Income Tax Act - Section 70 - Subsection 70(5) | s. 107.4(4) establishes floor for FMV proceeds under s. 70(5) of a trust capital interest that has vested indefeasibly | 97 |
29 May 2018 STEP Roundtable Q. 9, 2018-0744111C6 - Vested Indefeasibly
For purposes of the 21-year deemed disposition rule, a trust does not include a trust "all interests in which … have vested indefeasibly". What...
Catherine Brown, "Vested Indefeasibly: Its Importance for Tax Purposes", 2006 Canadian Tax Journal, Issue No. 4
Framework for determining indefeasible vesting
[T]he following may serve as a useful framework to determine whether an interest is ‘vested...
18 December 2013 External T.I. 2011-0414841E5 F - All interests vested indefeasibly
The trust indenture of a discretionary trust will be modified for it to become a non-discretionary trust, in order to avoid the application of the...
30 June 1994 External T.I. 9408895 - TRUSTS - MEANING OF "VESTED INDEFEASIBLY"
Respecting a question as to whether that all interests in a Trust had vested indefeasibly for purposes of the predecessor of para. (g), CRA...
The Queen v. Boger Estate, 93 DTC 5276, [1993] 2 CTC 81 (FCA)
Heald JA summarized findings of the trial judge (p. 5279), which he later adopted (at p. 5281) as being "accurately stated":
- that an interest is...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 70 - Subsection 70(9) | 287 |