CRA recognizes that an individual and their registered plans can constitute multiple beneficiaries under the 150 MFT beneficiary test

Reg. 4801(b) requires a mutual fund trust to have at least 150 beneficiaries each holding one block of units with an aggregate fair market value of at least $500. CRA indicated that where an individual, her TFSA, her RRSP and her spouse’s RRSP (to which she had contributed) each held a block of units, they would be considered to be four beneficiaries for these purposes. It stated:

There is no requirement to look through the registered plan trust.

It also noted:

Notwithstanding our general view described above, we note that the CRA has previously applied … GAAR … in situations where mutual fund trust status was artificially achieved to facilitate abusive tax avoidance.

Neal Armstrong. Summary of 8 June 2020 External T.I. 2019-0822901E5 under Reg. 4801(b).