The deceased, who was a subscriber to an RESP of which his two-year old child was the beneficiary, devised and bequeathed all his property to a trust for the benefit of that child. Regarding the transfer of the RESP to the testamentary trust, CRA stated:
[A] subscriber … includes each individual, other than a trust (the "original subscriber") who has subscribed to the plan with the promoter and, after the death of that individual, any other person (including the estate of the original subscriber) who acquires the individual's rights as a subscriber to the plan … .
…[I]f a trust acquires rights from the original subscriber after the original subscriber’s death as a subscriber to the plan, or if a testamentary trust makes contributions to the RESP after the death of the original subscriber, that trust will be a subscriber … .