CRA notes that a s. 94(3) trust can cause a trust of which it is beneficiary to be subject to Part XII.2 tax

A non-resident trust, which is deemed to be resident for various purposes under s. 94(3)(a), is nonetheless considered to be a “non-resident person” for purposes of the application of Part XII.2 tax to a resident trust of which it is a beneficiary. It seems quite anomalous that a resident trust would be subject to Part XII.2 tax on the basis of the non-resident status of a beneficiary which is itself subject to full Part I tax under under s. 94(3).

Neal Armstrong. Summary of 9 February 2017 External T.I. 2016-0657531E5 under s. 210 – designated beneficiary – para. (a).