16 February 2012 External T.I. 2011-0430841E5 - U.S. Grantor Trusts -- summary under Article 4

CRA indicated that if s. 94(3) applied to deem a US grantor trust with US-resident settlors to be a resident of Canada, then Art. IV(6) of the Canada-US Convention would not apply to dividends paid to the grantor trust by a Canadian corporation as both that corporation and the trust would be residents of Canada.