Contributor
Contributor
A person (other than an exempt person but including a person that has ceased to exist) that, directly or through a partnership of which it is a member, makes:
- a contribution to a non-resident trust, by a transfer or loan of property (except an arm's-length transfer); or
- an indirect contribution to a non-resident trust:
- by a transfer or loan of property (except an arm's-length transfer) as part of a series of transactions, where it is reasonable to consider that the transfer or loan relates to another transfer or loan of property (except an arm's-length transfer) made to the trust by another person or partnership, or
- by contracting an obligation to make a transfer or loan of property (except an arm's-length transfer), where it is reasonable to consider that the obligation relates to another transfer or loan (except an arm's-length transfer) made to the trust by another person or partnership.
Note
- An exempt person is, as a rule, a person exempted from paying income tax.
- A trust that contributes to another trust at a given time is deemed to have made the contribution with each person or partnership that is a contributor to the trust at that time.
- A partnership that contributes to a trust at a given time is deemed to have made the contribution with each person or partnership that is a member of the partnership at that time.