28 June 1993 T.I. (Tax Window, No. 32, p. 11, ¶2605)

A capital gain realized by a trust will be allocated in accordance with the trust deed or, if the trust deed is silent, to the income beneficiaries. In particular, if the definition of income in the trust deed excludes capital gains, the trustees generally can allocate such gains to the capital beneficiary

The election under s. 118.1(6) is available in respect of the gift of an equitable interest in a trust.