Supreme Court agrees that trusts have the same residency test as corporations

The Supreme Court has found that, as with a corporation, the place of residence of a trust is wherever its "central management and control" (respecting important decisions) is exercised, which is not necessarily the jurisdiction of residence of the trustee(s).

The Court also has confirmed British case law that if a shareholder exercises the central management and control of a corporation from another jurisdiction than where the board of directors meets, the corporation is resident in that other jurisdiction.

Scott Armstrong.  Summary of Fundy Settlement v. Canada, 2012 SCC 14, under ITA s. 2.