In a July 30, 2015 Technical Interpretation (2015-0596841E5, Kohnen, Phillip, 613-670-8916), CRA was asked whether voluntary contributions of capital to a Trust by its beneficiaries, in the same proportion as their fixed income and capital interests in the Trust, would cause it to lose its status as a Personal Trust.
CRA noted that the definition of a Personal Trust (Subsection 248(1)) requires that no beneficial interest was acquired for consideration payable to the Trust, or anyone else who has made a contribution to the Trust. CRA indicated that the additional contributions of capital to the Trust would cause it to lose its status as a Personal Trust.
For further information see VTN Monthly Tax Update Seminar, Issue No. 410