NRT Tax Traps And The Non-Specialist
Advisor1
—Michael Goldberg, Tax Partner, Minden Gross
LLP, MERITAS law firms worldwide and June 2016 founder of
"Tax Talk with Michael Goldberg", a quarterly conference
call about current, Number 641 relevant and real-life tax
situations for professional advisors who serve high net worth
clients.
This article is the third instalment in a four-part series.
The fourth and final instalment will appear in next month's
issue of Tax Notes.
In the second instalment of the Series we began the arduous task
of providing a high-level review of the Section 94 NRT Rules with a
focus on just how easy it is for a contributor to make a
contribution to a trust under these rules. Since not all
contributions to trusts will engage the Section 94 NRT Rules, in
this, the third instalment of the Series, we will consider the
types of contributions that will cause otherwise Pure NRTs to
become Section 94 NRTs subject to tax in Canada.
