Author: Brendan Forrest

Canada Revenue Agency comments on relief from double tax under Articles XIII(7) and XXIV(2) of the Canada-U.S. Tax Treaty on deemed disposition of U.S. real estate

Published by Brendan Forrest

In Canada Revenue Agency (“CRA”) Views document number 2021-0922301I7, the CRA considered a Canadian-resident trust deemed to dispose (for Canadian income tax purposes) of U.S. real property on its 21-year anniversary. The CRA was asked whether: (a) the trust could…