Informal Request for ATI Records Previously Released

Organization: Canada Revenue Agency

Year: 2023

Month: December

Request Number: A-2020-123545

Request Summary: All documents regarding the Canada Revenue Agency (CRA) consideration of, or Ruling on, the application of subsections 107(2), 107(2.1) and 107(5) of the Income Tax Act regarding the distribution of property by a trust directly or indirectly to a non-resident beneficiary and whether the distributions were subject to the general anti-avoidance rule in section 245 of the Income Tax Act.

Disposition: Disclosed in part

Number of pages: 342

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This information is collected for statistical purposes and is published annually on the Government of Canada Info Source website. (www.infosource.gc.ca)

Academia: Those who are engaged in higher education and who require information for research purposes.

Business (Private Sector): Those who are employed by the private sector, including lawyers and consultants, and who require information for their business or on behalf of another individual.

Media: Those who are employed by a radio or television company, a newspaper or magazine, or any online newspaper or blog, etc., and who require information for media purposes.

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Please note To the extent possible, the institution will return the requested records in the format selected, but it may not be able to accommodate all electronic formats due to size limitations.
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Please Note: Institutions will work to respond to your request for this previously released package as soon as practical.
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