Trust Shares Determinable if Benefits Match Investments, Exempting from Income Tax Act Section 164 Requirements.

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....Assessment of trust - whether the assessee Trust is a determinate Trust or indeterminate Trust? - Once the benefits are to be shared by the beneficiaries in proportion to the investment made, any person with reasonable prudence would reach to the conclusion that the shares are determinable. Once the shares are determinable amongst the beneficiaries, it would meet with the requirement of the law, to come out from the applicability of Section 164 of the Act. - HC....