2022 Ruling 2022-0937661R3 F - 104(4) and pipeline transaction -- summary under Subsection 245(2)

The Directorate considered that a distribution of the property of a trust under s. 107(2) before its 21^st anniversary to a corporate beneficiary held by a newly-formed trust was an abuse of s. 104(5.8) and ruled that all the property held by the new trust would be deemed to be disposed of at FMV on such 21^st anniversary. See Quinco Financial.