11 October 2013 APFF Roundtable, 2013-0495651C6 F - Revenu fractionné -- summary under Subsection 104(13)

A discretionary family trust with Father, Mother and a 15-year old Child as beneficiaries, holds a building with two premises – the first leased to an arm's length tenant; and the second, to a professional corporation of Father and Mother. Could the split income tax be avoided if the trust distributed only the income from the first premises to Child, and the income from the second premises to Mother? Before providing a more apodictic answser in the body, CRA stated in the summary: "Yes, when the trust indenture allows such attribution [sic, allocation and distribution]."