The CRA says that a rollover under subsection 73(1) is not available for an individual’s transfer of property to a trust supposedly governed by subparagraph 73(1.01)(c)(ii) (an “alter ego” trust) if the trust provisions prohibit the distribution of income to the individual while he or she is a bankrupt. CRA technical interpretation 2017-0737181E5 (March 30, 2022)