30 June 1994 External T.I. 9408895 - TRUSTS - MEANING OF "VESTED INDEFEASIBLY" -- summary under Paragraph (g)

Respecting a question as to whether that all interests in a Trust had vested indefeasibly for purposes of the predecessor of para. (g), CRA referred to The Queen v. Boger Estate, 93 DTC 5276 (FCA), and stated:

In order to apply this interpretation it is necessary to ascertain whether the beneficiaries' respective interests in the Trust had vested without either a condition subsequent or determinable limitation attached thereto.

This condition appeared to be satisfied, at the latest, following the death of XX, as following that time it appeared that the Trust was not revocable.

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