A s. 75(2) trust rather than its contributor is the relevant taxpayer for s. 40(3.6)(b) basis adjustment purposes

If a capital loss on the redemption of trust shares which otherwise would be attributed to a contributor to the trust under s. 75(2) is instead denied under s. 40(3.6) on their redemption, the denied loss will be added to the adjusted cost base of the remaining shares of the corporation in question held by the trust rather than being added to the ACB of any shares of the corporation held by the contributor.

Neal Armstrong. Summaries of 10 October 2014 APFF Roundtable, Q. 5, 2014-0538241C6 F under s. 40(3.6) and s. 146(1) – earned income.