On January 1, 2022, Mr. Bilodeau settled a trust for his daughter Jane, who became age 17 in 2022. The trust was documented by a written agreement. There are three trustees, Mr. Bilodeau, Mrs Bilodeau, and a long-time family friend. The trust provided that the trustees had complete discretion to distribute any portion of the capital or annual income of the trust to the beneficiary. ITA: 104 Mr. Bilodeau transferred the following assets into the trust on January 1, 2022: (a)$250,000 cash; and (b)1,500 shares of Successful Retailers Ltd. (Retailers), a corporation that is incorporated in Canada and is a CCPC with no GRIP balance. The original cost of the shares about 23 years ago when they were purchased by Mr. Bilodeau was $17 per share. At the date of transfer the fair market value was $500 per share. Mr. and Mrs. Bilodeau run the retail business from a location in downtown Toronto. The trust immediately purchased a 5% bond with the $250,000 cash. Interest of $12,500 is payable on December 31. The amount of dividends paid on the Retailers shares for each of 2022 and 2023 is $40,000. The dividends were received only from income eligible for the small