A trust that is a limited partner of a partnership (“LP”) providing back office support to a general partnership of accounting professionals (“Partnership”) as its only source of income has a minor disabled beneficiary who qualifies as a “preferred beneficiary.” Does the definition of “split income” include income of the trust allocated under s. 104(14) to that beneficiary? CRA stated:
[T]he income allocated to a preferred beneficiary under subsection 104(14) in the fact scenario you have provided is not included in the definition of split income and therefore is not subject to tax on split income.