CRA considers that refundable tax in an RCA trust cannot be recovered through setting up a replacement trust

CRA is not amenable to recovering the build-up of recoverable tax in an RCA trust (securing retirement benefits through LCs held in the trust) by winding it up and establishing a new RCA trust that acquires new LCs to secure the promised member benefits: a mere "change of the custodian… does not result in the termination of the RCA trust itself (or a distribution from the RCA)."

Neal Armstrong. Summary of 7 July 2014 T.I. 2013-0511061E5 under s. 207.5(2).