An inter vivos trust is approaching its 21-year anniversary. Before the anniversary, the trust distributes property under 107(2) to Canco, a corporate beneficiary, which is wholly-owned by another inter vivos trust. The other trust was just formed, and so it will not be deemed to dispose of its property for another 21 years. The GAAR committee considered this scenario in the context of a ruling request and decided that GAAR would apply. 2016 CTF Roundtable Q1.