CRA requires that redemption notes issued by an open-end REIT have a term not exceeding a specified maximum

CRA ruled that the conversion of a listed REIT from a closed-end unit trust under s. 108(2)(b) to an open-end unit trust under s. 108(2)(a) through the addition of a retraction right to the unit terms would accomplish that objective and would not result in a disposition of trust property or of units. The ruling letter specified a requirement that the term of any notes issued and transferred to a retracted unitholder would not have a term of greater than X years from the date of issue.

Neal Armstrong. Summary of 2023 Ruling 2022-0958681R3 under s. 108(2)(a).