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