Trust residence can be structured to be in a different jurisdiction than the ordinary location of the trustees

The appropriate application of the corporate residence test of central management and control to ascertaining trust residence is to look to the jurisdiction where the decision making over the corpus is exercised. This indicates that it is possible for a trust to be resident in a different jurisdiction than the ordinary location of its trustees or other decision makers – analogous, say, to a corporation with mostly non-Caymans directors being resident in the Caymans because that is where the high level decisions are made in board meetings.

Neal Armstrong. Summary of H. Michael Dolson, "Trust Residence After Garron: Provincial Considerations," Canadian Tax Journal, (2014) 62:3, 671-99 under Reg. 2601(1).