Chapter
CRA finds that an indemnity given by a Canadian NRT beneficiary regarding a trust distribution received from the trustee did not cause s. 94(2)(d) to apply
From Deyab v. Canada, 2020 FCA 222 by Sambif
Concepts
- Indemnity Application
"The Canadian-resident beneficiary of a factually non-resident trust (the “NRT”) will sign an indemnity, prior to the distribution by the NRT, which requires the repayment of the distribution to the t