Sachs v. The Queen, 80 DTC 6291, [1980] CTC 358 (FCA) -- summary under Subsection 104(14)

Where preferred beneficiary elections have been made jointly by a trust and the children of the settlor there has "been an exercise of the trustee's authority to pay the whole of the income for the taxation years in question to the children and to irrevocably confer on them the right to it "(per Thurlow, C.J.); "by completing the election under subsection 104(14), and by distributing dividends pursuant thereto ... the trustee has created a vested interest in the accumulating trust income" (per Heald, J.).