The Trust, which will be settled by an officer of its Manager, will invest principally in the limited partner units (Class A units) of a limited partnership (LP). A majority of the directors of the general partner (GP) will not be trustees of Trust. GP will be wholly-owned by the Manager, who also will be the sole trustee of the Trust.
Ruling that s. 253.1 will apply such that the acquisition of the limited partnership interest in the LP by the Trust will not, in and of itself, cause the Trust to be considered to be carrying on the business of the limited partnership for the purposes of s. 132(6)(b).