An individual has a non-registered account and is a holder of a TFSA and an annuitant of a RRSP. The individual is also a contributor to a spousal or common-law partner RRSP. The non-registered account and each of the registered plan trusts hold units of the same class of the mutual fund trust (“MFT”) that satisfy the requirement of being a block of units having a fair market value of at least $500.
CRA stated:
[T]here are four beneficiaries for purposes of satisfying the 150 beneficiary requirement. The individual and each registered plan trust count as a separate beneficiary.
Notwithstanding our general view described above, we note that the CRA has previously applied … GAAR … in situations where mutual fund trust status was artificially achieved to facilitate abusive tax avoidance.
The CRA summary noted:
There is no requirement to look through the registered plan trust.