Where a resident trust (other than a “reporting financial institution” (RFI), is a “passive non-financial entity” (Passive NFE), and has a “financial account” with an RFI, such RFI will have reporting obligations under Pt. XIX if one or more “controlling persons” are “reportable persons.” The s. 270(1) definition of “controlling persons” refers inter alia to the trust’s “settlors” and to a discretionary beneficiary to whom a distribution has been paid or made payable in the calendar year.