Canada Revenue Agency

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Transfers to a corporation can be costly. Beware of corporate attribution.

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Part III – Corporate Attribution This blog post has been written by Pritika Deepak, Associate at Fasken LLP. This is the last part of a three-part blog series which provides a high level overview of the attribution rules contained in the Income Tax Act (Canada)[1] (the “Act”). Part I, which addresses personal attribution and Part II, which speaks to trust attribution, can be found respectively at https://allaboutestates.ca/no-good-deed-goes-unpunished-by-the-cra/ and https://allaboutestates.ca/using-a-trust-watch-out-for-attribution/. Part….

Transfers to a corporation can be costly. Beware of corporate attribution. Continue Reading »

Business Succession Planning, Canada Revenue Agency, Estate Planning, Succession Planning, Tax Issues, Uncategorized

Is This a Bare Trust?

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Andrew Coates, Associate, Gowling WLG (Canada) LLP Today was supposed to be the due date for untold numbers of T3 returns and Schedule 15s for trusts known as “bare” trusts in existence on December 30, 2023. Not only was it going to be the first year that the Canada Revenue Agency (the “CRA”) required bare trusts to report their existence through the filing of a T3 return, but also the….

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Canada Revenue Agency, Estate Planning, Joint Tenancy, Tax Issues, Trusts, Uncategorized

Tax Considerations for Gifts of Art in Canada PART TWO

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Gwenyth Stadig, Associate and Upama Poudyal, Articling Student  – Gowling WLG (Canada) LLP This article forms part two of a two part series detailing the benefits and requirements of donating art for Canadian taxpayers to consider as part of their estate planning needs. Part one of this article series explored the benefits and three legal requirements for gifts of art. This article will continue the discussion on the requirements.   You can find….

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Canada Revenue Agency, Charitable Giving, Tax Issues

What Makes an Indigenous Trust Unique?

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What makes an Indigenous trust unique from other inter vivos trusts? Two factors in particular are worth noting: (1) the nature and involvement of the beneficiaries of the trust, and (2) the manner in which Indigenous entities as settlors can utilize the income attribution rule under s 75(2) and their tax-exempt status under s 149(1)(c) of the Income Tax Act…..

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Canada Revenue Agency, Tax Issues, Trusts

Executors: Holiday Elf or Grinch?

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                                             Photo Credit: Universal Pictures This blog has been written by Sandra Arsenault, Law Clerk at Fasken LLP If you are the lucky (or more often unlucky) person appointed to administer an Estate, you may have more stress than usual this holiday season. I wrote this blog in hopes….

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Canada Revenue Agency, Estate Administration, Estate Administration and Probate Applications, Executors, Family Conflict, Wills

Section 116 and Capital Distributions by Trust to Non-Resident

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When a trust makes a capital distribution to a non-resident beneficiary, the beneficiary is deemed to have disposed of a part or the whole of their capital interest in the trust.[2] Where the capital interest in the trust is “taxable Canadian property” (“TCP”),[3] the vendor of the TCP (i.e. the beneficiary who is deemed to be “disposing” of their interest in the trust) must apply for a clearance certificate from the Canada Revenue Agency (the “CRA”) under section 116, either in advance of the disposition or within 10 days of the disposition…..

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Canada Revenue Agency, Cottage, Estate Administration, Executors, International, Property, Real Estate, Tax Issues, Trusts
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