In the course of finding that transactions, including sales of income fund units by an RRSP trust to another income fund, entailed dispositions and transfers of beneficial ownership of the transferred units, Monaghan JA stated (at para. 130):
Where a trust transfers property, it is a disposition. This is true even if the transfer is to a beneficiary or another trust with identical beneficiaries: subparagraphs (e)(i) to (iii) of the definition of disposition in s. 248(1). The only exception is where legal title is transferred to a person that holds it as bare trustee and acts as agent for the owner with respect to all dealings with the property.