A Canadian-resident is receiving, for her lifetime, annual distributions of dividends from U.S. companies as an income beneficiary of a U.S. estate. Can those distributions be treated the same as dividends from Canadian companies? CRA stated:
Pursuant to paragraph 250.1(b)…, the trust’s “income” must be computed according to the rules of the Act. … Subsection 108(5)… provides that amounts included in the Taxpayer’s income under subsection 104(13)… shall be deemed to be income from property that is an interest in the trust and not from any other source. … [T]he income that the Taxpayer has received is deemed to be income from an interest in a trust; it does not retain its character as dividend income.