11 October 2013 Roundtable, 2013-0495801C6 F - Dividend Paid to Trust and Schedule 3 of T2 -- summary under Paragraph 186(1)(b)

The trust designates a taxable dividend it received on June 30, 2013 from Opco to its beneficiary, Holdco, whose year-end is June 30. 2013. A trust cannot make an s. 104(19) designation until its year end (December 31) since it is only then that it can be determined that it has been resident in Canada throughout the year. Accordingly, Holdco should include the amount of the taxable dividend in its return for June 30, 2014 year and pay the applicable Part IV tax.