2 June 2026 STEP Roundtable, Q.8

Policy Tabs

Summaries

Summary Under

Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(i) - Subparagraph 256(7)(i)(ii)

trustees of an alter ego trust who hold a power to encroach on capital hold discretionary authority with respect to the capital of the trust as described in s. 256(7)(i)(ii)

Often, the settlor of an alter ego or joint partner trust will be a trustee until such time as the settlor's incapacity or death, at which point...

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Summary Under

Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(2) - Paragraph 251.2(2)(a)

there is generally an acquisition of control of any trust-controlled corporation where an unrelated person becomes a replacement trustee

Regarding where the settlor of an alter ego or joint partner trust changes, e.g., upon the incapacity or death of the settlor, CRA indicated that...

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2 June 2026 STEP Roundtable, Q.8

Policy Tabs