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- Title
CANADIAN TAXATION OF INCOME EARNED AND DISTRIBUTED BY A SUBSECTION 94(3) TRUST.
- Authors
Schweitzer, Tony; Brodlieb, Jesse
- Abstract
Non-resident trusts with certain connections to Canada have long been subject to Canadian tax. Since 1999, the government of Canada has proposed to overhaul the Canadian taxation of non-resident trusts, most recently with draft legislation released on October 24,2012. The purpose of these new rules is to cast a wider net for the Canadian taxation of non-resident trusts. The authors briefly review trust residence issues and the taxation of non-resident trusts under the existing rules, and then present an in-depth discussion of the proposed legislation. The authors' main focus is on the taxation of income earned in and distributed by a non-resident trust that is deemed to be a resident of Canada for Canadian tax purposes. Different rules apply depending on the source of the income, the residence of the beneficiary, and whether the income is retained in or distributed by the trust.
- Subjects
CANADA; TAXATION of trusts; TAX laws; NONRESIDENTS; TRUST beneficiaries; INCOME tax laws
- Publication
Canadian Tax Journal / Revue Fiscale Canadienne, 2013, Vol 61, Issue 2, p461
- ISSN
0008-5111
- Publication type
Article