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ARTICLE · 06 DECEMBER 2012

Revised NRT Rules Expand Exemptions For Mutual Funds And Commercial Trusts

Borden Ladner Gervais LLP
Borden Ladner Gervais LLP
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November 21, 2012, Bill C-48, the Technical Tax Amendments Act, 2012, received first reading in the House of Commons. Bill C-48 includes, among numerous outstanding technical amendments to the Income Tax Act (Canada) (the "Act"), a revised version of the proposed amendments to the tax rules relating to non-resident trusts ("NRTs") in section 94 of the Act (the "Current NRT Proposals").

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November 21, 2012, Bill C-48, the Technical Tax Amendments Act, 2012, received first reading in the House of Commons. Bill C-48 includes, among numerous outstanding technical amendments to the Income Tax Act (Canada) (the "Act"), a revised version of the proposed amendments to the tax rules relating to non-resident trusts ("NRTs") in section 94 of the Act (the "Current NRT Proposals"). Several successive versions of the proposed amendments to section 94 have been released over a period of more than a decade. The Current NRT Proposals make several significant changes to the prior version of the proposed rules, which was released on August 27, 2010 (the "2010 Proposals") and discussed in detail in our November 2010 tax law bulletin.

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