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In particular, the REIT will be required to take into account in computing its income (a) any “foreign accrual property income” net of any “foreign accrual tax” deduction and (b) any capital gain (or capital loss) in respect of each capital property transferred or disposed of by the REIT in connection with such transactions. ...

Baker & McKenzie LLP, U.S. counsel to the REIT, will render an opinion in connection with the Closing in respect of the treatment of the REIT as a U.S. corporation under s. 7874. ...

Ruling Crombie has applied for an advance income tax ruling from CRA in connection with the Reorganization (see 2016-0660321R3). ...

In connection with the Transaction, unitholders will be entitled to receive a distribution per Unit in the following amounts: Class of Units1 Pre-U.S. ...

The REIT will withhold on account of the Mutual Fund Withholding Tax on the entire amount paid to a Non-Resident Holder in connection with the redemption. ...

Immediately after the REIT Disposition in accordance with the qualifying disposition rules, the adjusted cost base of a Resident Holder's REIT Units (as increased in connection with the Finance Trust Disposition) will be decreased by the REIT Transfer Percentage (being the percentage reduction in the fair market value of a REIT Unit as a result of the REIT Disposition), and the adjusted cost base of a Resident Holder's F17 Trust Units will be increased by the same amount (except to the extent that the Resident Holder's loss, if any, from a disposition of the REIT Units immediately before the REIT Disposition would have been denied under the "dividend stop-loss rules" – which are not expected to have a material impact). ...