Dixie Energy Trust asset sale and winding-up is structured to preclude any push-out to the unitholders of gain

Dixie Energy Trust, which is a listed Alberta unit trust holding U.S. oil and gas assets through U.S. subsidiaries, will close a sale of all its assets on December 29, 2014 and distribute all the net cash proceeds in the following year. It appears to be contemplated that not much will be payable in the way of Canadian taxes by the Trust as a result of the sale as it appears to be occurring as an asset sale by corporate subsidiaries. Although there is paltry disclosure on this point, the Canadian unitholders appear to be taking no direct risk on the Canadian tax consequences to them of the distributions as they will occur in 2015, i.e., after the 2014 disposition of the assets.

Neal Armstrong. Summary of Dixie Energy Trust Circular under Spin-offs and Distributions – Liquidations – Trust Liquidations.