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SmartREIT/OneREIT/Strathallen-- summary under REIT Mergers Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- REIT/Income Fund/LP Acquisitions- REIT Mergers OneREIT asset sale and merger into SmartREIT entails an allocation of recapture of depreciation to its existing unitholders Overview OneREIT is proposing to sell a substantial portion of its rental assets (held through subsidiary LPs) in a taxable sale to a third party (Strathallen) and then, as part of the same Plan of Arrangement, to be merged into SmartREIT (which is an Alberta unit trust and REIT) under s. 132.2. ...

Choice/CREIT-- summary under REIT Mergers Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- REIT/Income Fund/LP Acquisitions- REIT Mergers choice between cash redemption or s. 132.2 merger Overview The proposed acquisition of the REIT (which is a closed-end REIT holding most of its properties directly or through subsidiary LPs) by Choice Properties- which is an Ontario REIT holding a partial interest in a property-holding LP (Choice Properties LP)- would occur for aggregate consideration of approximately $1.7B in cash and Choice Properties units valued at around $2.1B. ...

Classification as REIT Mitchell, Williams, Selig, Gates & Woodyard, PLLC, U.S. counsel to the REIT, will render an opinion to the REIT to the effect that, commencing with its first taxable year ending December 31, 2018, the REIT is organized and operates in conformity with the requirements for qualification and taxation as a real estate investment trust under the Code, and that the REIT’s organization and current and proposed method of operation will enable it to continue to meet the requirements for qualification and taxation as a real estate investment trust under the Code. ...

Characterization as 2 instruments The US tax disclosure indicates that GFL will take the position that each unit will be treated as consisting of two separate instruments for Code purposes – and that if the unit were instead treated as a single instrument, a US holder could be required to recognize the entire amount of each instalment payment on the amortizing notes, rather than merely the portion of such payment denominated as interest, as income. ...