Section 107.4

Subsection 107.4(1) - Qualifying disposition

Administrative Policy

2017 Ruling 2016-0625301R3 - Merger of two related segregated fund trusts

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 138.1 - Subsection 138.1(1) - Paragraph 138.1(1)(a) reallocation by insurer of securities held for one segregated fund to being held for the second segregated fund effected their transfer to the second fund viewed as a deemed trust 120

2013 Ruling 2013-0492731R3 - qualifying disposition -mutual fund trust

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 132 - Subsection 132(6) MFT's trustee not to be a director of a sub 109
Tax Topics - Income Tax Act - Section 132.2 - Subsection 132.2(1) - Qualifying Exchange elimination of REIT subtrust through s. 107.4 transfer to new "in house" MFT and s. 132.2 merger of MFT into REIT 89

2013 Ruling 2013-0488351R3 - Conversion of a MFC to a MFT

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 132.2 - Subsection 132.2(1) - Qualifying Exchange conversion of MFC to MFT and subtrust elimination 150
Tax Topics - Income Tax Act - Section 21 - Subsection 21(1) election of GP to capitalize loss before elimination of subtrust 190

2013 Ruling 2011-0395091R3 - MFC to MFT Conversion

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17 October 2012 Ruling 2011-0428321R3 - qualifying disposition -mutual fund trust

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Paragraph 107.4(1)(a)

Administrative Policy

2018 Ruling 2018-0752811R3 - Transfer of Debt as Qualifying Disposition

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2017 Ruling 2017-0720591R3 - Re-org of a stapled commercial trust structure

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2004 Miscellaneous 2003-0053981R3 - XXXXXXXXXX

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) elimination of MFT corporate sub through creation of MFC and 132.2 merger 156
Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(1) - Paragraph 107.4(1)(h) immediate refinancing of drop-down subsidiary trust of MFT did not offend policy of para. (h) 219

Paragraph 107.4(1)(h)

Administrative Policy

2004 Miscellaneous 2003-0053981R3 - XXXXXXXXXX

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(1) - Paragraph 107.4(1)(a) qualifying drop-down of partnership units to subsidiary unit trust where s. 107.4(2)(a) was ousted due to units issuance 218
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) elimination of MFT corporate sub through creation of MFC and 132.2 merger 156

Subsection 107.4(2) - Application of paragraph (1)(a)

Paragraph 107.4(2)(a)

Administrative Policy

2017 Ruling 2016-0660321R3 - Reorg of REIT to simplify multi-tier structure

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 132.2 - Subsection 132.2(1) - Qualifying Exchange use of the s.132.2 merger and a renunciation of most of the units otherwise issuable on the merger in order to eliminate a REIT corporate subsidiary held through an LP and a sub-trust 924
Tax Topics - Income Tax Act - Section 98 - Subsection 98(3) drop down of LP 1 into LP 2 followed by immediate s. 98(3) wind-up of LP 1 into LP 2 and GP of LP1, followed by immediate taxable sale by GP to LP 2 120
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) no taxable benefit where wholly-owned partnership renounces the right to have consideration paid for the redemption of its shares in its limited partner (a mutual fund corporation) 309
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition no disposition on conversion of general to limited partnership or adding right of renunciation of a MFT unitholder 158
Tax Topics - Income Tax Act - Section 132.2 - Subsection 132.2(3) - Paragraph 132.2(3)(g) - Subaragraph 132.2(3)(g)(vi) - Clause 132.2(3)(g)(vi)(C) - Subclause 132.2(3)(g)(vi)(C)(I) renunciation by subsidiary partnership of transferee MFT of units that otherwise would be issuable on the redemption of its incestuous holding in transferor MFC 217

2003 Ruling 2003-00498C

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Articles

Geraint Thomas, Alastair Hudson, "Chapter 7: The Nature of a Beneficiary’s Interest", The Law of Trusts,” Oxford University Press, 2004

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Subsection 107.4(3) - Tax consequences of qualifying dispositions

Administrative Policy

20 March 2013 External T.I. 2013-0474861E5 - Subparagraph 107.4(3)(a)(i) election

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2003 Ruling 2003-00498C

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(2) - Paragraph 107.4(2)(a) s. 107.4(2)(a) applies where drop-down by MFT of corporate sub to sub trust for no consideration 214

7 December 2000 External T.I. 2000-003268 -

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