As discussed by us in a previous communication posted on our website, Bill C-10 proposes new tax rules for investments in “non-resident trusts” effective 2007. We noted that if Bill C-10 were enacted in its current form, investments by tax-exempt Canadian registered pension plans (or by master trusts in which such pension plans pool their investments) in a non-exempt non-resident trust could, in some circumstances, result in significant tax liabilities to the pension plan (or master trust).

type Tax News - May 2008 - Non-Resident Trust ("NRT") Rules and Pension Plans