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ARTICLE · 08 NOVEMBER 2010

NRT Alert: Finance Releases Revised Non-Resident Trust Legislation

Borden Ladner Gervais LLP
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On August 27, 2010, the Department of Finance Canada released for public consultation a package of draft legislation (Draft Legislation) to implement various tax measures announced in the 2010 federal budget as well as several previously announced tax initiatives, including tax rules relating to non-resident trusts (NRT) and foreign investment entities (FIE).

CanadaTax
Peter Wong
Peter Wong
Stephanie Wong
Stephanie Wong
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On August 27, 2010, the Department of Finance Canada released for public consultation1 a package of draft legislation (Draft Legislation) to implement various tax measures announced in the 2010 federal budget as well as several previously announced tax initiatives, including tax rules relating to non-resident trusts (NRT) and foreign investment entities (FIE). Since their first introduction in 2000, the draft rules applicable to NRT and FIE have been controversial. The proposed rules now included in the Draft Legislation represent the seventh version of these rules.

In broad terms, it appears that the Draft Legislation was intended to revise the NRT and FIE proposals to reflect much of the criticism and submissions that the Canadian government had received from various business organizations and other interested parties. In particular, the legislation confirms, as announced in the 2010 federal budget, that the previously proposed FIE rules have been abandoned in

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