Before going on to indicate that at trust could be considered to be actively engaged in the activities of a general partnership for purposes of the specified member definition on the basis of the conduct of the partnership’s management by its trustee, CRA stated:
Subsection 104(1) provides, inter alia, that, unless the context otherwise requires, a reference in the Act to a trust includes a reference to the trustee who controls the trust property. Consequently, in determining whether a trust, which is a member of a partnership, is actively involved in the partnership's activities, we are of the view that the degree of involvement of the trustee in the partnership's activities can be taken into account.