An individual settled a trust with a gold bar, which it will hold until its winding-up. Such settlor is a contingent beneficiary (i.e., will receive the bullion if all the other beneficiaries predecease that individual, so that s. 75(2)(a)(i) is satisfied. In indicating that for the purposes of s. 107(4.1)(b), "subsection 75(2) was applicable..." despite no income or capital gain ever being attributed pursuant to s. 75(2), CRA stated: