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Brookfield (BPY)/BPO-- summary under LP Acquisitions of Corporations Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- REIT/Income Fund/LP Acquisitions- LP Acquisitions of Corporations Offer by Brookfield Property Partners of cash, units or exchangeable LP units for shares of BPO [see also BPY IPO] Overview BPY, which "beneficially owns" approximately 49% of the common shares of BPO, and two of its indirect subsidiaries ("Brookfield Office Properties Exchange LP, or "Exchange LP;" and Brookfield Property Split Corp., or "BOP Split"), are making an "any or all" offering for the remaining common shares of BPO, in consideration for BPY units or cash subject to the overall mix of consideration being fixed at around 67% units and 33% cash. ...

ExxonMobil/InterOil-- summary under Canadian Buyco Summary Under Tax Topics- Public Transactions- Mergers & Acquisitions- Cross-Border Acquisitions- Inbound- Canadian Buyco Acquisition by ExxonMobil Canadian purchaser of InterOil for fixed-value ExxonMobil shares and escrowed cash payment subject to reduction based on subsequent resource estimate Overview It is proposed that a newly-incorporated B.C. subsidiary of ExxonMobil will acquire InterOil under a Yukon Plan of Arrangement. ...

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. ...