26 July 1989 Income Tax Severed Letter AC57770 - Bare Trusts

By services, 22 July, 2022
Official title
Bare Trusts
Language
English
Document number
Citation name
AC57770
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657651
Extra import data
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"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1989-07-26 08:00:00",
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Main text
5-7770
                                                 G. Kauppinen
                 19(1)                           (613) 957-3495

July 26, 1989

Dear Sirs:

This is in reply to your letters dated March 22 and April 10, 1989 regarding bare trusts. In these letters you have indicated that, in your view, our position regarding the taxability of bare trusts as reflected in our response to Question 32 of the 1988 Round Table has created many practical problems.

As you may be aware, bare trusts were the subject of a paper given by C.B. Darling of Revenue Canada, Taxation at the 1989 Corporate Management Tax Conference. Copies of this paper may be obtained from the Canadian Tax Foundation.

In this paper it was indicated that we intend to review our position regarding the taxation of bare trusts and, until this review is completed, taxpayers may rely on our published position in IT-216 , IT-437 and 1 . In other words, where property is transferred to a bare trust the settlor will be considered to be the owner of the property for income tax purposes.

Yours truly,

for Director Financial Industries Division Rulings Directorate