CRA indicates that a Canadian corporation controlled by a s. 94 (deemed resident) trust is not a CCPC
13 June 2016 - 1:24am
The fact that a trust which is factually non-resident is deemed to be resident in Canada for the purposes specifically listed in s. 94(3)(a) will not cause a Canadian corporation controlled by it to qualify as a Canadian-controlled private corporation.
Neal Armstrong. Summary of 10 June 2016 STEP Roundtable, Q.7 under s. 125(7) - Canadian-controlled private corporation.