CRA will not accommodate a trust which merely distributes all it can

Where a trust distributes all of its share of the accounting profits of a partnership but its share of the taxable income of the partnership is higher, it will be subject to trust-level taxation on the excess.

Neal Armstrong. Summary and translation of 2015-0595851C6 F under 9 October 2015 APFF Financial Strategies and Instruments Roundtable, Q. 6.