On January 1, 2023, Russell created a trust for the benefit of his 22-year old child. Russell gifted 500 shares of X Ltd., a Canadian public corporation, to the trust. At the time of the gift, the 500 shares were valued at $240,000. Russell had purchased the shares in 2008 for $90,000.

During 2023, the trust received $8,000 of eligible dividends on the X Ltd. Shares. The trust sold the shares in July for $360,000 to a third party.

REQUIRED

1. What are the tax consequences to Russell of the gift of the shares of X Ltd to the trust?
2. If all the income is kept in the trust and not distributed, calculate the combined tax payable for the trust. Assume the lowest combined marginal tax rate is 25% and the top combined marginal tax rate is 50%.
3. Suppose that the trust is instead created for the sole benefit of Russells spouse, instead of his child. Please repeat parts a) and b) under this assumption.