From time to time, tax practitioners read technical interpretations issued by the Income Tax Rulings Directorate of the CRA which are not only unexpected, but cause great concern. An example is Technical Interpretation 2004-0062291E5, which was released by the CRA during the week of April 12, 2004. In this technical interpretation, the CRA sets out its views on non-resident discretionary trusts, which are not deemed to be resident in Canada under the proposed non-resident trust ("NRT," pronounced by tax geeks as "NERT") legislation.

Read more by clicking the download button.