The Husak family trust has only one beneficiary, Martin Husak, the 32 year old son of the settlor, Dimitri Husak. It is an inter vivos trust and its only asset is a rental property with a fair market value equal to its capital cost. The trust is required to distribute all of its income to Martin. During the year ending December 31, 2020, the property will have net rental income, before the deduction of CCA of $32,000. Maximum CCA for the year will be $26,000. Dimitri is considering having the trust sell the rental property at the end of 2020. If that is done, there will be recapture of CCA of $65,000. He has asked you to compare the tax consequences for both Martin and the trust if (1) the sale takes place in December 2020 and (2) the trust continues to hold the property. Ignore the possibility that some of the income received might be subject to the TOSI.
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