1. Alpha (as trustee of the Alpha Unit Trust) owns taxable land. 2. The sole unitholder of the Alpha Unit Trust is Bravo (as trustee of the Bravo Unit Trust). The unitholders of the Bravo Unit Trust are— Absentee Beneficiary 1, who has a 40% unitholding; and Non-absentee Beneficiary 1, who has a 40% unitholding; and Absentee Beneficiary 2, who has a 20% unitholding. 3. The Bravo Unit Trust is an absentee trust because it has at least one absentee beneficiary—see paragraph (b) of the definition of absentee trust. The Alpha Unit Trust is also an absentee trust because its unitholder, Bravo, is an absentee beneficiary holding an interest as trustee of an absentee trust—see paragraph (b) of the definition of and paragraph (b)(ii) of the absentee trust definition of absentee beneficiary. 4. The Alpha Unit Trust and the Bravo Unit Trust are in a chain of trusts—see section 3D. 5. The absentee proportion of interests in land subject to the Alpha Unit Trust is calculated as follows— Step 1—calculate Absentee Beneficiary 1's interest in the land Multiply Absentee Beneficiary 1's interest in the Bravo Unit Trust (40%) by Bravo's interest (as trustee of the Bravo Unit Trust) in the Alpha Unit Trust (100%). 40% × 100% = 40%.
1. Alpha (as trustee of the Alpha Unit Trust) owns taxable land. 2. The sole unitholder of the Alpha Unit Trust is Bravo (as trustee of the Bravo Unit Trust). The unitholders of the Bravo Unit Trust are— Absentee Beneficiary 1, who has a 40% unitholding; and Non-absentee Beneficiary 1, who has a 40% unitholding; and Absentee Beneficiary 2, who has a 20% unitholding. 3. The Bravo Unit Trust is an absentee trust because it has at least one absentee beneficiary—see paragraph (b) of the definition of absentee trust. The Alpha Unit Trust is also an absentee trust because its unitholder, Bravo, is an absentee beneficiary holding an interest as trustee of an absentee trust—see paragraph (b) of the definition of absentee trust and paragraph (b)(ii) of the definition of absentee beneficiary. 4. The Alpha Unit Trust and the Bravo Unit Trust are in a chain of trusts—see section 3D. 5. The absentee proportion of interests in land subject to the Alpha Unit Trust is calculated as follows— Step 1—calculate Absentee Beneficiary 1's interest in the land Multiply Absentee Beneficiary 1's interest in the Bravo Unit Trust (40%) by Bravo's interest (as trustee of the Bravo Unit Trust) in the Alpha Unit Trust (100%). 40% × 100% = 40%.
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