CRA further clarifies that a qualifying s. 94(2)(t) sale of Canadian shares effects an immediate change in trust residency
If a non-resident trust is "tainted" as a resident trust under s. 94(2)(g) by being issued shares by a resident corporation, it potentially can re-acquire non-residency status under s. 94(2)(t) if it makes a qualifying sale of the shares. When this occurs, it changes its status immediately, so that it is non-resident for the stub period beginning with the sale, is resident for the stub period before the sale, and has a potential deemed disposition of its property under the emigration rule (s. 128.1(4)) as a result of the status change.
2013-0509111E5 confirmed the above results. However, a 2019 Interpretation has essentially amended 2013-0509111E5 by getting rid of a confusing passage that suggested that for certain purposes the trust remained a deemed resident until year end. The 2019 interpretation confirms that the sale triggers the change back to non-resident status for all relevant purposes.
Neal Armstrong. Summary of 17 January 2019 Internal T.I. 2018-0781041I7 under s. 94(2)(t).