Upsizing an Investment Trust Without Losing Its Trust Tax Status

Under current authorities, there are at least three ways in which depositors can upsize an existing multiple-beneficiary investment trust without jeopardizing its trust classification for tax purposes and without creating a new trust for the additional assets. These strategies include (i) upsizing a recently created investment trust within a short period of time to facilitate the organization of such trust, (ii) adding identical assets to an existing investment trust in the same proportions as the assets it currently holds, and (iii) upsizing the trust without taking advantage of market variations to improve the investment of the beneficiaries.

In addition, administrative ...