How would s. 75(2) apply where proceeds or income of property of an alter ego trust that had been contributed by the settlor was reinvested?
CRA indicated that, in light of the s. 248(5) substituted-property rule, the attribution would continue to apply if securities were repeatedly sold and reinvested in other securities, so that the income including taxable capital gains arising on the substituted property would continue to be attributed to the settlor under s. 75(2). However, any income or loss derived from the reinvestment of the earnings (the "second generation income") would not be attributed to the contributor. Thus, the income earned on the substituted-property securities is attributed pursuant to s. 75(2) as first generation income, but any income earned on that income will not be attributed.