Rights offering of the MINT Income Fund is non-taxable

The MINT Income Fund will distribute rights to acquire its units to its unitholders - other than US unitholders, who are ineligible under the 1933 Act to receive certificates for rights, and will instead receive sales proceeds (if any) from the sale of the rights certificates that they would have received if the rights had been registered under that Act.  The rights will be TSX-listed, implying that they are anticipated to have a positive value.

The tax disclosure indicates that the rights issuance "should have no immediate tax consequences for a Unitholder," so that this issuance should not give rise to a taxable benefit under s. 105(1).  This may turn on the proposition that any positive value of the rights received by a unitholder (or the cash proceeds in lieu thereof in the case of a US unitholder) will be offset by dilution in the value of the units held.

Neal Armstrong.  Summary of the MINT Income Fund preliminary short form prospectus under Offerings - Rights Offerings.