Trustees may be required to report contingent beneficiaries under Reg. 204.2(1)
Regulation 204.2(1) will require disclosure of any person who is a "beneficiary" of the trust. Propep stated obiter that a person should be regarded as a "beneficiary" throughout the Act if that person was "beneficially interested" in the trust, and stated that "[a] person who has a contingent right to the capital or income of a trust is 'beneficially interested' for the purposes of the Act." Propep was adopted in 2014-0538021C6 in interpreting s. 55(5)(e)(ii).
There is an expressed concern that, starting with the 2021 taxation year, trustees for many trusts may be required to report contingent beneficiaries.
Neal Armstrong. Summary of Kate Harris and Balaji (Bal) Katlai, “New Trust Disclosure Rules: The Unfolding of the Propep Nightmare,” Tax for the Owner-Manager,” Vol. 20, No. 4, October 2020, p. 7 under Reg. 204.2(1).