Subsection 270(1)
Controlling Persons
Administrative Policy
29 November 2022 CTF Roundtable Q. 10, 2022-0950581C6 - Common Reporting Standard
Where a resident trust (other than a “reporting financial institution” (RFI), is a “passive non-financial entity” (Passive NFE), and has a...
Paragraph (a)
Administrative Policy
10 June 2025 Internal T.I. 2023-0970361I7 - Interpretation of “controlling persons” definition
Trust B, a Canadian resident discretionary trust, was the only beneficiary of Trust A, also a Canadian resident discretionary trust. Both trusts...
Reportable Jurisdiction Person
Articles
Robert E. Ward, "The Common Reporting Standard Comes to Canada", Tax Management International Journal, Vol. 46, No. 9, 8 September 2017, p. 538
Evasion of FATCA and CRS reporting (p. 540)
Perhaps the greatest commonality between CRS and FATCA is the ease with which both regimes may be...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 271 - Subsection 271(1) | 138 |