Unlike the s. 94(1) definition, the s. 251.1(3) definition does not specify that a contributor includes a decedent. Is one included? CRA responded (TaxInterpretations translation):
[D]epending on the context, a deceased person could be considered as having at any time made, a loan or transfer of property, either directly or indirectly, in any manner whatever, to or for the benefit of a trust. This position applies to transfers of property made as a result of the death of a taxpayer and to inter vivos loans or transfers of property made by a taxpayer prior to his or her death.