CRA considers that contributions of capital to a trust may constitute consideration

The definition of a personal trust refers inter alia to "an inter vivos trust no beneficial interest in which was acquired for consideration payable directly or indirectly to…the trust." Without much explanation, CRA indicated that where the beneficiaries of an inter vivos (non-unit) trust make additional contributions of capital to the trust in proportion to their respective fixed entitlements to a percentage of trust capital and income, it could not confirm that these contributions do not disqualify the trust as a personal trust.

Neal Armstrong. Summary of 30 July 2015 T.I. 2015-0596841E5 under s. 248(1) – personal trust.