Revocable transfer defined: retransfer rights or the power to re assume control render a transfer revocable and attributable to the transferor.

Definitions of transfer and revocable transfer govern attribution for the purposes of sections 96, 97 and this provision. "Transfer" includes any settlement, trust, covenant, agreement or arrangement. A transfer is revocable where it contains a provision for direct or indirect re transfer of income or assets to the transferor, or where it gives the transferor any right to re assume power, directly or indirectly, over any part of the income or assets.

---

---

---