Précis: This was an appeal from a decision of the Tax Court blogged earlier on this sight. The Tax Court decision was on an interlocutory motion pursuant to Rule 58 of the Tax Court of Canada Rules (General Procedure). The issue was whether the trustee of several self-administered RRSPs was the “purchaser” (for the purposes of subsection 116(5) of the Income Tax Act (the “ITA”)) of certain private company shares acquired by the RRSPs from non-residents. As “purchaser” the trustee would be potentially liable for any unremitted withholding taxes (none had been remitted in respect of the transactions).
Olympia Trust v. R. - FCA: RRSP Trustee “purchaser” for 116(5) withholding on share purchasesREAD MORE »