IDEAS home Printed from https://ideas.repec.org/a/ctf/journl/v62y2014i3p671-699.html
   My bibliography  Save this article

Trust Residence After Garron: Provincial Considerations

Author

Listed:
  • H. Michael Dolson

    (Felesky Flynn LLP, Edmonton)

Abstract

The recent decisions in Garron and the adoption of the central management and control test for trust residence may have a material impact on interprovincial tax planning, if for no other reason than the resulting CRA audit project targeting Alberta-resident trusts. This article examines the theoretical basis for the imposition of residence-based provincial income taxes on trust income, revealing at least one acceptable but nevertheless flawed alternative. This article then turns to an examination of central management and control in the context of trusts, and discusses how this test could be applied in future cases.

Suggested Citation

  • H. Michael Dolson, 2014. "Trust Residence After Garron: Provincial Considerations," Canadian Tax Journal, Canadian Tax Foundation, vol. 62(3), pages 671-699.
    • Handle: RePEc:ctf:journl:v:62:y:2014:i:3:p:671-699
    as

    Download full text from publisher

    File URL: https://www.ctf.ca/EN/Publications/CTJ_Contents/2014CTJ3.aspx
    Download Restriction: no
    ---><---

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:ctf:journl:v:62:y:2014:i:3:p:671-699. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    We have no bibliographic references for this item. You can help adding them by using this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Jim Lyons (email available below). General contact details of provider: https://www.ctf.ca/EN .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.