A discretionary family trust holding the growth shares can allocate a capital gain on a sale among several beneficiaries, each potentially claiming their own exemption. The tax on split income rules introduced in 2018 removed most of the ordinary income-sprinkling benefit, but the QSBC capital gains exemption remains available in defined circumstances. Note the 21-year deemed disposition: a trust settled now comes with a date attached, and that date should be in the plan from the first day rather than discovered in year nineteen.