The CRA doesn’t like it when trusts purport to roll out property to a Canadian corporation to which a non-resident beneficiary has assigned his or her capital interest. See technical interpretation 2017-0683021I7 (which I discuss here), 2021-0879021C6 and the Preston family trust cases (docket no. 2020-641(IT)G), docket no. 2020-642(IT)G) and docket no. 2020-643(IT)G)).
Philip Friedlan and Adam Friedlan “Preston Family Trust II: The 21-Year Rule and Non-Resident Beneficiaries” 22:2 Tax for the Owner-Manager (April 2022)
