Principal Issues: Whether the CRA would be able to provide an interpretation that a certain rebate to be paid by a dealer to unitholders in a mutual fund trust would not be included in the income of the mutual fund trust pursuant to paragraph 12(1)(x) and subsection 12(2.1) of the Act.
Position: No, the CRA would not be able to provide such a technical interpretation.
Reasons: The wording of paragraph 12(1)(x) and subsection 12(2.1) are such that these provisions might apply in the situation described.