30 May 2018 External T.I. 2017-0717981E5 - Clearance certificate for a non-resident -- summary under Subsection 116(3)

A former resident of Canada (and after her death, her non-resident estate, which had exclusively non-resident beneficiaries) received CPP, interest and RRSP/RRIF payments from Canadian sources. Before addressing the issue of whether the non-resident executors are required to apply for CRA to issue a clearance certificate under s. 159, CRA indicated that there was an obligation of the non-resident beneficiaries who were disposing of capital interests in the estate that were taxable Canadian property, as well as of the estate if it was distributing taxable Canadian property, to apply for a s. 116 certificate.