CRA accepts that the mere right of the beneficiary to replace the trustees does not give her de jure control of a trust subsidiary

CRA accepts that the mere right of a sole beneficiary to replace the (unrelated) trustees does not give her de jure control of a corporation held by the trust.  But what if the trust deed also gives her the right to receive advance notice of major decisions (so that she can replace them if she doesn’t like what they are proposing to do)?

Without answering specifically, CRA indicated that a beneficiary with the removal right potentially has de jure control if her rights under the trust deed also accord her "an influence over the decisions of the trustees."

Neal Armstrong.  Summary of 1 March 2014 T.I. 2013-0494981E5 F under s. 251(2)(b)(i).