Principal Issues: 1. When would a taxable dividend designated in respect of a beneficiary of a trust pursuant to subsection 104(19) be considered to have been received by the beneficiary?
2. Would the corporate beneficiary of the trust and the dividend payer be connected with respect to the dividend designated under subsection 104(19)?
Position: 1. At the time that is the end of the taxation year of the trust in which the dividend was received by the trust.
2. At the end of the taxation year of the trust, the corporate beneficiary and the dividend payer would not be connected corporations.
Reasons: 1. The conditions of subsection 104(19).
2. Paragraph 8 of IT-269R4.