Units of a unit trust consist of one class issued in two series, with those of the first series having a fair market value (FMV) of less than $25 per unit and the second having an FMV between $25 and $100 per unit. Given that s. 248(6) did not apply, and regarding the requirement in Reg. 4801(a)(i) that there be at least 150 unitholders each of whom holds at least a block of units of a class that meets the test in Reg. 4801(a), CRA stated:
