851.37. Where an amateur athlete trust holds property on behalf of a beneficiary who dies in a year, the trust is deemed to have distributed, immediately before the death, to the beneficiary, an amount equal to(a) where the trust is liable to pay tax under Part XII.2 of the Income Tax Act (Revised Statutes of Canada, 1985, chapter 1, 5th Supplement) in respect of the year, 64% of the fair market value of all property held by it at that time; and
(b) in any other case, the fair market value of all property held by it at that time.