a trust deemed in respect of a communal religious organization.

A deemed trust is created by statute, such as the Excise Tax Act (the Act).

The Court held that a deemed trust “is, in a sense a legal fiction”.

Accordingly, this decision confirms the existence of dissociation, at least in part, for the concept of a deemed trust.

(a) a person whose property is subject to the deemed trust created by subsection 3.6.1 (1); or

Section 126 also creates a deemed statutory trust such that the Crown holds a deemed trust over the assets of the debtor for any amount that the debtor fails to remit under the Employment Insurance Act.

(a) a person whose property is subject to the deemed trust created by subsection 24.1 (1); or

Section 224(1.3) ITA defines “security interest” for the purposes of the deemed trust.

227(4.1) ITA and to review the cases in which the scope of the deemed trust has been considered.

We are seeking a declaration that this deemed trust applies to the Wind Up Deficit of the Sears Canada Plan.

(a) to a person or entity whose property is subject to a deemed trust created by section 33; or

(a) to a person or entity whose property is subject to a deemed trust created by section 33; or

A series of questions and answers is published on the CRA webpage Information on deemed trust.

However, the further claim will be limited to legal fees, disbursements and other costs related to the deemed trust.

In these situations, the CRA may assert its deemed trust priority and act to recover these amounts.