The grantor retained annuity trust is an artifact of the US gift and estate tax, which Canada does not have. A GRAT works by transferring appreciation above a statutory interest rate free of gift tax. With no gift tax to arbitrage, the mechanism has nothing to bite on here.

Worse, transferring property to a Canadian trust is itself a deemed disposition at fair market value — you trigger the gain on the way in, which is the opposite of the American outcome. And a Canadian trust carries the 21-year deemed disposition: the trust is treated as selling its assets every 21 years. That date should be written into the plan on day one, not discovered in year nineteen. The shape in section 04 transfers; this specific vehicle does not.