Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016.
Trustees not necessarily a group (pp. 158-9)
[T]he CRA has relied on Consolidated Holding as establishing a presumption that trustees act in concert as a group. This presumption ignores two key factual findings in Consolidated Holding—namely, that Harold and Robert Gavin were held to be acting as a group with respect to their personal shareholdings in Consolidated Holding and that the terms of the will provided that they could bind the decision of the third trustee. If the trust had required the unanimous consent of the trustees and the trustees had no other connection, it is unclear whether the court would have come to the same conclusion. [fn 125: Mark Brender,…2007 Conference Report…31:1-49.]