10 October 2014 APFF Roundtable, 2014-0534841C6 F - Majority-interest beneficiary -- summary under Majority-interest beneficiary

Where a person is not a beneficiary, but it affiliated with a beneficiary with a majority interest in a trust, is that person also included in the definition of "majority-interest beneficiary"? CRA stated (TaxInterpretations translation):

A person (other than a trust [later referencing s. 251.1(4)(d)(iii)]) which does not have an interest qua beneficiary in the income nor an interest qua beneficiary in the capital of a trust could be a majority interest beneficiary in certain cases. This is the case if such person is affiliated with a person or persons who have interests qua beneficiary in the income of the trust having a fair market value exceeding 50% of the fair market value of all the interests qua beneficiary in the income of the trust or who have interests qua beneficiary in the capital of the trust having a fair market value exceeding 50% of the fair market value of all the interests qua beneficiary in the capital.

The Explanatory Notes example (re Philip and Muriel) on s. 251.1(3) confirms this interpretation.

Topics and taglines
Topic
Income Tax Act - s. 251.1(3) - Majority-interest beneficiary
Tagline
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
324129
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
344457
Extra import data
{
"field_editor_tags": [],
"field_roundtable_subquestion": "3",
"field_stub": false,
"field_legacy_header": "<a id=\"2014-0534841C6\"></a><a href=\"/?p=31491\">10 October 2014 APFF Roundtable, Q. 3, 2014-0534841C6 F</a> [includes affiliates with no actual beneficial interest]"
}