CRA confirms that a majority-interest beneficiary of a trust does not have to be a beneficiary

CRA has confirmed that a "majority-interest beneficiary" of a trust includes a person which is not itself a beneficiary, but is affiliated with an actual majority interest beneficiary.

Although not discussed, this would suggest, for example, that there will be a loss restriction event respecting a subsidiary unit trust of a REIT every time that another person becomes affiliated with the REIT, e.g., the REIT incorporates a real estate nominee (the exclusions in s. 251.2(3) are not much help) or, respecting a family trust, when a family member has the misfortune to wed or give birth (see s. 251.1(5)(a)(ii)).

Neal Armstrong. Summary of 10 October 2014 APFF Roundtable, Q. 3, 2014-0534841C6 F under s. 251.1(3) - majority-interest beneficiary.