8 September 2017 External T.I. 2014-0549771E5 - Article XXIX-A:3 -- summary under Subparagraph 251(2)(b)(i)

CRA found that in the situation where a U.S. parent was the trustee of a U.S. trust whose beneficiary was a U.S. Opco, that U.S. Opco qualified as a related person. In particular, having regard to the deeming by s. 104(2) of a reference to a trust as being a reference to the trustee, the Trust controlled US Opco by virtue of its trustee (US parent) controlling US Opco.