Where a non-resident of Canada sells taxable Canadian property (TCP), the purchaser of such property can be liable for withholding tax under s. 116. In Olympia Trust Company v. The Queen, 2014 TCC 372, the trustee of a self-directed RRSP acquired TCP from a non-resident. The CRA assessed the trustee (not the annuitant) under s. 116 for withholding tax, which had not been remitted by the trustee (or the annuitant) on the sale. The Tax Court of Canada (TCC) upheld the assessment on the basis that the trustee was “the purchaser” of the TCP for purposes of s. 116(3) and s. 116(5) (see paragraph 42). This result followed because, although the RRSP trustee was not the beneficial owner of the TCP purchased, the trustee did have possession, legal title, and management of all of the RRSP’s property – including the cash used to purchase the TCP and the TCP itself following the purchase (see paragraph 31).