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 Colubriale v. Canada, 2005 FCA 329 by Un actionnaire vend un immeuble à sa société

Concepts

  1. Indemnity

    "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

  2. Indebtedness

    "[I]n order for paragraph 94(2)(d) to be applicable, inter alia, the undertaking must be given to ensure the repayment of a loan or indebtedness incurred by the other person at the relevant time. In t

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 | Colubriale v. Canada, 2005 FCA 329 | Bifalgorithm | Bifalgorithm