19 April 1990 T.I. (July 1990 Access Letter, ¶1324)

After reconsidering its technical interpretation of 7 December 1989, RCT was of the view that where an income beneficiary has agreed to bear the burden of a trust's tax liability arising out of a designation under s. 104(13.1) or (13.2), the payment of the taxes by the beneficiary would not by itself result in a contribution to the trust for the purposes of s. 108(1)(i) or a gift to the trust for purposes of s. 122(2)(d).

After reconsidering its technical interpretation of 7 December 1989, RC was of the view that a designation under s. 104(13.1) or (13.2) and the payment of the resulting taxes out of the trust income, will not affect the status of a trust described in s. 70(6)(b) or 104(4)(a).