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2017 Ruling 2016-0660321R3- Reorg of REIT to simplify multi-tier structure-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition no disposition of partnership interests or property on conversion of general to limited partnership or adding right of renunciation of a MFT unitholder The Declaration of Trust of a Canadian REIT (the “Fund”) will be amended to provide for the consolidations of its units following s. 132.2 merger transactions, for the in specie redemption of Fund units through distribution of securities of a Fund subsidiary including units of a mutual fund trust received in connection with one of such s. 132.2 merger transactions and adding the right of a subsidiary to renounce its right for most of the Fund Units otherwise issuable on one of the s. 132.2 merger transactions. ...

7 December 2000 Ruling 2000-0040053- Disposition- Mutual Fund Trust Units-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition new unit classes contemplated and their attributes similar In connection with refusing to rule because the proposed transactions related to a wide range of funds for which documentation had not been provided, CCRA went on to provide general comments. ...

2018 Ruling 2018-0778961R3- Partial transfer to new funds-- summary under Subsection 107.4(2.1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107.4- Subsection 107.4(2.1) use of s. 107.4(2.1) in transfer of portion of MFT to a new MFT In connection with an arm’s length acquisition transaction, apparently of the business of managing exchange-listed mutual fund trusts, holders of Series D or O Units of some of such funds (the Participating Public Funds) wish to become investors in corresponding “New Funds” and thereby continue to have their investments managed by the previous managers, rather than remaining as investors in the Participating Public Funds and having their investments managed by the new managers. ...

In connection with the s. 88(1) winding-up, the Ruling Letter stated: Lossco1 will be formally dissolved before the end of the first taxation year of Profitco commencing after the commencement of the winding-up of Lossco1. ...

All leasing revenue received has been reported by Subco 1 as active business income, representing income that is earned in connection with the Subco 1 Transferred Business 1. ... All leasing revenue received by Subco 1 from the XX businesses has been reported by Subco 1 as active business income, such income being earned in connection with the Subco 1 Transferred Business 1. ...

In connection with the transfer by the Partnership of all the Property to Newco, Newco will assume a portion of the Liabilities equal in amount to the fair market value of Non-85(2) Property as sole consideration for such transfer (with a joint election being filed under s. 22 respecting the accounts receivable) and as consideration for the Partnership's transfer to Newco of the 85(2) Property, Newco will: (i) assume the "Remaining Liabilities" (i.e. the portion of the Liabilities remaining after the transfer of the Non-85(2) Property), (ii) and issue the "Promissory Notes" and the "Preference Shares" to the Partnership (with a joint s. 85(2) election being made). ...

Immediately prior to the dividends paid to ForeignHoldco in connection with or prior to the liquidation of LabuanOpco, the total of all of the net earnings of LabuanOpco for its preceding years from the active business carried on by it in Malaysia, net of any prior dividends, was equal to or exceeded the amount of those dividends. ...

Partnership is the plan sponsor and a participating employer in connection with each of the Employee Unfunded Benefit Plans. ...

The Explanation further states: Based on the information provided, since there is a direct and clear connection between the Dealer's Fee and the services performed by that Dealer to facilitate the initial sale of the […] Shares, the Dealer's services are predominantly "arranging for" a financial service as provided under paragraph (l) of the definition of financial service and would not be excluded from the definition by any of paragraphs (n) through (t) including paragraphs (p), (q), (q.1) and (r.4). ...

Rulings Application of revenue tests (paras. b and (c)) where nil revenue Assumptions made in connection with rulings that the Mezzanine Loan and LP interest in New LP of Partnership will qualify in a particular taxation year as real or immovable property to Partnership or Trust, as the case may be, pursuant to subparagraph (a)(i) of the definition of "real or immovable property" include that in the year New LP does not earn any gross REIT revenue or its only gross REIT revenue is rents and interest not exceeding 25% of its gross REIT revenue. ...