Department of Finance Canada
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Legislative Proposals Relating to the Income Tax Act

Taxation of Non-Resident Trusts and Foreign Investment Entities

October 2003


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Table of Contents

Income from business or property.

Loan to non-resident - Controlled foreign affiliate.

Capital gain from disposition of property.

Convertible property.

Cost of certain property the value of which is included in income.

Adjustments to cost base.

Death of a taxpayer.

Inter vivos

transfers by individuals transfers by individuals.

Trusts - attribution.

Definition of "eligible property".

Share for share exchange.

Exchange of shares - reorganization.

Amalgamations - non-resident trusts and foreign investment entities.

Amounts to be included in respect of share of a foreign affiliate.

Non-resident Trusts.

Foreign Investment Entities - Imputed Income.

Foreign Investment Entities - Mark-to-market.

Foreign Investment Entities - Accrual.

Foreign Investment Entities - Relief from Double Taxation.

Foreign affiliates.

Partnerships and their members.

Contribution of property to partnership.

Disposition of partnership property.

Trusts and their beneficiaries.

Disposition by taxpayer of capital interest.

Qualifying disposition.

Trusts - definitions.

Deduction in respect of dividend received from foreign affiliate.

Part-year residents.

Tax payable by Inter vivos trust.

Foreign tax credit.

Immigration.

Exempt corporations.

Assessment and Reassessment.

Penalties.

Withholding and remittance of tax.

Rents and timber royalties - optional method of payment.

Foreign reporting requirements.

Returns in respect of foreign property.

Returns respecting foreign affiliates.

Due diligence exception.

Definitions and certain arrangements under civil law.

Inter vivos transfer of property by an individual.

Disposition by taxpayer of capital interest.