He summarizes subsection 75 (2) as follows:
Subsection 75(2) of the Income Tax Act[1] is an attribution rule that can apply in respect of property (or property substituted for that property) contributed to a trust by a person (the “contributor”). The subsection will apply if the property “is held on condition” that it
(1) may revert to the contributor,
(2) may pass to persons to be determined by the contributor, or
(3) shall not be disposed of except with the contributor’s consent or in accordance with his or her direction.
For those of us who are not tax specialists, this stuff isn't simple, but Mr. Loukidelis explains the rule clearly and concisely. You can read it here.
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