Allocation-to-redeemer rulings (p. 12)
- The allocation-to-redeemer methodology for allocating capital gains to a redeemed unitholder is supported...
Purpose test applies at time the terms are established (p. 10)
- The original Explanatory Notes referenced “one of the main purposes for the...
Abuse addressed by s. 132(5.3)(a), and response in practice (pp. 6-8)
- S. 132(5.3)(a) addressed in part the potential for abuse arising from a...
Potential to not receive a full refund (p. 13)
- Where the amount of an MFT’s realized capital gains throughout a taxation year divided by the...
Background to s. 132(5.31) (p. 16)
- S. 132(5.3)(b) produced an inappropriate result for exchange-traded funds (ETFs) where a market maker, in...
ETF difficulty in detecting whether a unitholder has become a majority-interest beneficiary (pp 25-26)
- A fund can conclude that it did not...
Permanent tainting if momentary breach of any condition (p. 26)
- A trust breaching any of the conditions in paras. (a) or (b) of the definition of...
Timing of applying tests under ss. (c)(ii) to (iv) (p. 30)
- Although ss. (c)(ii) and (iii) do not expressly address when eligible entity status is...
Eligible group entity status in bank-controlled ETF group (pp. 31-32)
In the scenario where the asset manager for a mutual fund corporation (MFC)...
Payment and allocation discretion consistent with fixed interest status (p. 32)
- The discretion of pay distributions at different times (e.g., to...
Issues with computing trust ATI (p. 36)
- The adjusted taxable income (ATI) definition in relation to a trust requires adding back (under Variable...