A trust, unlike a person or a corporation, is not a legal entity... A trust is simply a legal relationship between the trustee, who holds legal title to the subject property of the trust and the beneficiaries, who hold beneficial title to that subject property. However, there is one exception to the general rule: a trust is a legal entity for tax purposes. Subsection 104(2) of the Income Tax Act (Canada) specifically provides that a trust is an individual for tax purposes and, thus, is considered a separate taxpayer.