In indicating that property held by a trust of which a corporation is the sole beneficiary is not considered assets of the corporation for the purposes of the test in subpara. (c)(i) of the definition of "qualified small business corporation share," CRA stated:
[P]ursuant to subparagraph 110.6(1)(c)(i) of the definition of QSBC, [CRA] is of the view that the phrase "attributable to assets used principally in an active business carried on … by the corporation" should be interpreted to refer to the fair market value of assets owned by the corporation. In other words, the corporation's beneficial interest in the trust is not an asset used principally in an active business carried on by the corporation or a corporation related to it, regardless of how the trust uses the property it holds.