The appellant trusts appealed income tax reassessments for the 2006 and 2007 taxation years, arguing they were resident in Alberta and subject to Alberta provincial tax.
The Minister of Finance reassessed the trusts as residents of Ontario.
The court applied the central management and control test to determine trust residency.
The court found that the trustees in Alberta performed primarily administrative functions, while the actual management and control of the trust property was exercised by a beneficiary and professional advisors in Ontario.
The appeals were dismissed.
