Northern Property REIT proposes to acquire True North REIT under s. 132.2, with exchangeable unitholders offered a s. 97(2) election

Northern Property REIT ("NPR" - an Alberta trust), is proposing to acquire True North REIT (an Ontario trust) under an Alberta Plan of Arrangement involving minimal corporate steps. A substantial portion of the equity investment in True North REIT is in the form of exchangeable units in six subsidiary LPs. Holders are given the choice of exchanging their LP units for NPR units or for new redeemable units of the same partnerships, i.e., LP units which are redeemable for NPR units. The tax disclosure treats an exchange for such new redeemable LP units as being eligible for a s. 97(2) rollover.

Neal Armstrong. Summary of Northern Property REIT and True North REIT Circulars under Mergers & Acquisitions – REIT/Income Fund/LP Acquisitions – Section 132.2 Mergers – REIT Mergers.