998R3. For the purposes of paragraph c.4 of section 998 of the Act, a trust is, at any time, a master trust if, at all times after its creation and before that time, it fulfils the following conditions:(a) it is resident in Canada;
(b) its sole undertaking consists in investing its funds;
(c) it never borrowed money, except where the borrowing is for a term of not more than 90 days and it is established that the borrowing is not part of a series of loans or other transactions and repayments;
(d) it never accepted deposits; and
(e) each of its beneficiaries is a trust governed by a registered pension plan, a pooled registered pension plan or a deferred profit sharing plan.