11 October 2019 APFF Roundtable Q. 15, 2019-0812741C6 F - TOSI and interest income earned by a trust -- summary under Paragraph 108(5)(a)

CRA noted that the preamble to s. 108(5)(a) provides that that rule does not apply to s. 120.4, and stated: “Thus, for the purposes of section 120.4, the character of the amounts allocated by a trust will be maintained.” (See also Archer-Shee v. Baker, Gilhooly and Kemp below, which were not discussed by CRA.)