Transactions and Special Rules
Certain transactions may be made in favour of the trust or by the trust. Such transactions, as well as certain special tax rules, can have significant consequences.
This section provides information about the following rules:
- the cross-border anti-surplus-stripping rule for trusts;
- the rollover rule, which allows transferors to transfer property without immediate tax consequences;
- the income attribution rule, which requires that trusts issue an RL-16 slips in certain cases;
- the attribute trading restriction, which prevents the trading of corporate tax attributes;
- thin capitalization rules, which limit the ability of trusts to deduct certain types of interest;
- restrictions applicable to certain investment trusts with respect to stapled securities.
It also provides information about the following types of losses:
- losses on the disposition of property involving an affiliated person, which are generally not deductible;
- non-deductible losses in the calculation of the adjusted taxable income for AMT purposes.