18 June 2015 STEP Roundtable Q. 7a, 2015-0572141C6 - 2015 STEP– Q7-Deemed Res Trust-subsection 94(10) -- summary under Paragraph 94(3)(a)

///?p=37586#Q7b">19 June 2015 STEP Roundtable, oral Q.7(a)): Will an individual who becomes resident in Canada for the first time, and who has previously contributed property to a non-resident trust, thereby being considered a resident contributor, cause s. 94(3)(a) to deem the trust to be resident from January 1 of that taxation year? CRA stated:

Since the individual has previously contributed property to the trust, the individual will be a contributor. Since the individual is a contributor and is resident in Canada, the individual will be a resident contributor.

Therefore, the non-resident trust will be deemed [by s. 94(3)(a)] to be resident in Canada throughout the taxation year, even if the taxation year commenced before the individual became a resident of Canada.

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