Provincial trust residency tested – Taxpayer prevails

A trust is not a legal entity, but rather the expression of a relationship where legal ownership of property is in the hands of a trustee, and beneficial entitlement lies with the trust’s beneficiaries.  Still, a trust is a taxable entity – so where should it be taxed?

Prior to 2012, it was not uncommon to hear it suggested that a trust is resident where the trustee is resident.  Assuming this to be correct, a settlor of a trust could potentially achieve tax savings merely by appointing a trustee in a favourable jurisdiction.  

SCC clarifies trust residency

Then came the Supreme Court of Canada (SCC) in Fundy Settlement.  In that case, Canada sought tax jurisdiction over a trust with almost half a billion dollars of capital gains, Canadian-resident beneficiaries and a trustee resident in Barbados.  It probably goes without saying that the Barbados tax system was much more generous to the taxpayer.

The SCC ruled that there is no legal rule that the residence of a trust invariably must be the residence of the trustee.   Instead, the court held that, akin to corporations, residence should be determined based on where the central management and control of the trust actually takes place.  On the facts, it was ruled that the purported trustee was simply directed from Canada.

While the substance of Fundy Settlement addressed jurisdiction between two sovereign nations, the principles apply similarly at a sub-national or inter-provincial level.  This past June, a judgment from Newfoundland and Labrador took guidance from this earlier case, though coming to a much different result for the trust taxpayer.   

From Newfoundland to Alberta

In 1987, Craig Dobbin founded CHC Helicopter Corporation, a transportation company servicing the oil and gas industry in Canada and abroad.  

The business was very successful, sufficiently so that in 2002 an estate freeze was implemented, a central component of which was a transfer of shares into the newly settled “Discovery Trust”.  The beneficiaries and trustees were Mr. Dobbin’s five adult children, most or all of whom were residents of Newfoundland and Labrador. 

In 2006 the trust was amended, including appointment of a successor trustee Royal Trust (RT), a corporation resident in Alberta.  Mr. Dobbin had been experiencing health issues at that time, and died later that year.  From his death through 2008 a series of transactions were undertaken to wind up the corporate interests held by the estate.  RT filed its 2008 trust tax return as a resident of Alberta.  

In 2012, the Canada Revenue Agency reassessed the trust as being resident in Newfoundland, calculating the shortfall of provincial tax at $8.8 million, plus arrears interest of almost $1.5 million.  The trust appealed the reassessment to court.

Improper tax motivation?

CRA’s position was that the Dobbin children made all trust decisions, instructing RT which merely served an administrative function.  The principle investigator’s report went so far as to conclude that RT was appointed “solely” to resituate the trust to Alberta.

This last point the judge considered to be irrelevant.  Referring to the oft-cited 1936 case of the Duke of Westminster, it is a person’s right to order affairs to reduce taxes.  It was Mr. Dobbins’ prerogative to amend the trust as he did, intentionally bringing it under Alberta tax jurisdiction.

Still, there remained the matter of whether Royal Trust factually exercised central management and control.  After reviewing the material transactions, the judge concluded that it had fulfilled its obligations.  Though some documents and processes were initiated by others, RT acted independently in reviewing all transactions in order to make informed decisions that protected the best interests of the beneficiaries.  

As to the assertion that the taxpayer had an improper tax motivation, the judge found on the contrary that the investigator’s negative view compromised the integrity of the review and in turn the foundation for the reassessment. 

Estate as the designated beneficiary – An estate-planning lawyer’s perspective

“Make sure to designate a beneficiary on RRSPs, RRIFs and TFSAs so the money doesn’t fall into the estate.”

It’s such familiar guidance in investment and financial planning that it would be foolish to suggest otherwise. Or would it?

I recently had an exchange with a financial advisor whose client’s lawyer recommended the estate as the named beneficiary. It was a young family with a single child and nothing else remarkable.

Unusual though that recommendation may appear, I myself offered the same advice to some of my clients in my past estate-planning law practice. Then as now, beneficiary designations help bypass probate tax and estate creditors, but may be cast in a different light when considering the following countervailing points. [See Callout Box on Quebec below]

Tax onus on registered retirement savings plans (RRSPs)/registered retirement income funds (RRIFs)

A person named directly as beneficiary is entitled to the gross value of an RRSP/RRIF, with the tax liability falling to the estate. Though the named beneficiary has a joint liability under the Income Tax Act (Canada) for the proportionate amount of the estate’s tax, the Canada Revenue Agency would likely only bother pursuing such a course if the estate is insolvent. There is no provision for the estate itself to claim contribution from the RRSP/RRIF beneficiary.

This would not be an issue where the beneficiary/ies of the RRSP/RRIF and the estate are identical, but could be a serious concern in a situation such as a second marriage, whether on first or second death of spouses.

Flexible spousal rollovers

It may be desirable to have RRSP/RRIF proceeds come into an estate in order to take advantage of a deceased’s graduated tax brackets, rather than have an immediate rollover to a spouse. This could be particularly effective if the death occurs early in the year (i.e., there is little other income). Otherwise, the RRSP/RRIF simply adds on to the surviving spouse’s own registered funds, with potentially higher future tax cost to fully deplete (whether in life or at death).

Generally, the estate and surviving spouse can still elect to roll the excess (not included in the estate) to the spouse.

Amending and revoking

The Will gathers all beneficiary designations together in one place, centralizing control through that one instrument. Otherwise, the person would have to deal with the administrative rules, paperwork and potential delays in dealing with each financial institution. It remains that person’s prerogative to amend/revoke the Will, with the requirements of testamentary capacity being the same for a Will as for beneficiary designations.

On divorce (though not necessarily on separation), spouse entitlements in a Will are generally revoked (although this may vary by province) without having to execute a new Will. On the other hand, designations with financial institutions are not automatically revoked, even in the face of apparent explicit terms in an executed separation agreement. In fact, there is plenty of case law where this has been fought. (Even so, one should be tactful if raising this point with spouse-clients who are otherwise presently in wedded bliss.)

Inheritance contingencies

Trust terms in a Will can be tailored for later issue/grandchildren, whether as additions to the distribution or as stand-ins for one or more predeceasing directly named beneficiaries. For beneficiary designations, the default is generally that if AB, CD and EF are RRSP/RRIF beneficiaries and AB predeceases, CD and EF share equally under survivorship. That may not be the satisfactory expected result if AB has children whom the deceased would have wished to include.

If a target beneficiary has creditor and or matrimonial concerns (presently or as caution against future developments), trust terms may be attached to insulate against that exposure.

For spendthrift concerns (e.g., gambling, drinking, profligate), trust terms could be laid out, maybe to establish a short- or long-term allowance rather than a lump sum.

Transfers to minor beneficiaries or disabled beneficiaries will likely not be adequate as direct beneficiary entitlements, and may be detrimental in terms of impairing provincial support amounts (for the disabled), limiting investment options (requiring an annuity to age 18 for minors), losing control of distributed monies, and likely requiring consultation/approval of government authorities.

Estate liquidity

Absent cash in the estate (e.g., it consists solely of a house and other non-monetary assets), it may require someone to post the funds for the probate tax (to be eventually reimbursed) in order for the executor to take control of the estate assets and begin realizing on them.

Inter vivos or testamentary trust?

As a final thought, an estate is a testamentary trust that is taxed using graduated brackets. Assuming a principal beneficiary (e.g., a surviving spouse) is at a higher bracket than the estate, the cost of probate may be effectively negated by lower taxes on income generated from estate investments. In the past, this could potentially be carried on for many years, but after 2015 will generally only be available for the first 36 months of the estate.

Another alternative may be to have designations directed to a trust that is separate from the estate, with the result that probate and creditor concerns may be circumvented. The lost use of the estate’s graduated brackets should be factored into this latter approach, perhaps by directing some of the RRSP/RRIF proceeds to the estate or by providing the trustee with power to disclaim entitlement to some extent, in order to allow such RRSP/RRIF funds to fall into the estate.

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Callout Box – Quebec residents

Based on a Supreme Court of Canada ruling in 2004, financial institutions generally will not accept beneficiary designations by Quebec resident annuitants, forcing such registered plan proceeds to fall into the deceased’s estate.  While a Will is a key planning tool for all Canadians, the mandatory involvement of the estate for registered plans in Quebec reinforces this need, and underlines the considerations expressed in this article.

Last chance for trust planning in 2015

What to do with capital gains in testamentary trusts

With the passage of Bill C-43 in December 2014, most testamentary trusts will be subject to top marginal tax rates. The two exceptions are the first 36 months of a graduated rate estate and a qualified disability trust for a beneficiary who meets the criteria for the disability tax credit.

For most testamentary trusts, the new tax rates kick in on December 31, 2015. While trustees cannot change the law, they may be able to take planning steps to mitigate the damage, at least in the case of investments carrying unrealized capital gains.

Advisors managing such investments should reach out to trustees to inform them about appreciated holdings, so they can take action before it’s too late.

Changes: Timeline and cost

Until now, the main tax distinction among personal trusts has been the way they came into existence. Inter vivos trusts, those created while a person is living, are subject to top marginal brackets and use a calendar year-end. Testamentary trusts are created under a person’s will, and had been entitled to graduated tax bracket treatment. They could also choose a non-calendar year-end.

Both these tax advantages (and others) for testamentary trusts have now been eliminated. As a quick phase-in, existing testamentary trusts will have a deemed year-end this December 31 to bring them in line with calendar year-ends thereafter.

These changes will affect income earned annually in future, understanding that a trust is subject to the combined federal-provincial personal tax rates in the province where it is resident. On the federal component alone, the tax will almost double on the first dollar of income for testamentary trusts for 2016 and beyond, given that the lowest federal bracket is 15% and the highest 29%.

For capital gains, the federal increase will be 7% (since only half of capital gains are taxable). Here are the net differences based on combined rates in each province.

Table: Combined federal-provincial tax rates on capital gains

Province    Top bracket     Low bracket   Difference
BC                      22.9%              10.0%              12.9%
AB                     19.5%               12.5%              7.0%
SK                      22.0%              13.0%              9.0%
MB                     23.2%              12.9%              10.3%
ON                     24.8%              10.0%              14.8%
QC                     25.0%              14.3%              10.7%
NB                     23.4%              12.3%              11.1%
NS                      25.0%              11.9%              13.1%
PE                      23.7%              12.4%              11.3%
NL                      21.2%              11.4%              9.8%

Taking action on capital gains

It may be possible for capital gains to be managed in the face of this development. If a trust holds investments with as yet unrealized capital gains, the trustee may trigger some or all those gains through dispositions.

To be clear on the application of the new rules, there will be a deemed year-end on December 31, but not a deemed disposition of capital assets. This means a trustee must take steps to cause actual dispositions while graduated brackets remain applicable.

For securities, extra care should be exercised to allow for the three business days from trade date to settlement date to ensure gains are realized before the trust’s year-end. As well, trades by the trust and related parties in the month before and after must be carefully scrutinized, lest the superficial capital loss rules be inadvertently triggered, potentially undoing the plan.

For trusts with a non-calendar year-end, there will be two year-ends in 2015. So, it is doubly critical to act with haste for such trusts, as with each passing day, planning opportunities are expiring. There is no grandfathering or carryforward that will make those low rates available in 2016 or later. Simply put, the last opportunity for these trusts to access graduated brackets is in 2015.

Revisiting planning options

Preferential tax treatment has been a useful feature of testamentary trusts for almost half a century. In some situations, it may have been a by-product of other planning priorities such as managing disability needs, controlling asset distribution or providing for minors. Elsewhere, the tax aspects may have been central to the plan. Either way, trustees will begin looking at whether current trusts can or should continue, which may mean more asset movements to come.