Domestic SIFTs

ROI/Dream Hard Asset

Merger of ROI Canadian High Income Mortgage Fund, ROI Canadian Mortgage Income Fund and ROI Canadian Real Estate Fund into Dream Hard Asset Alternative Trust and termination of their forward/mirror fund structure
Overview

Return on Innovation Advisors Ltd. ("ROI Capital") agreed with DREAM Asset Management Corporation ("DREAM"), a subsidiary of DREAM Unlimited Corp. (TSX:DRM), that DREAM would acquire the rights to manage the ROI Public Funds and the privately held ROI IPP. There will be a reorganization of the Distributing ROI Funds and their relevant underlying "Reference Funds" involving the transfer of assets of each Distributing ROI Fund to the newly-formed Trust (an Ontario open-end unit trust with conventional retraction terms and targeted to be a mutual fund trust) in exchange for units of the Trust. As a result of the transaction, all the assets of the Distributing ROI Funds (including those of the relevant underlying reference funds) will be combined in the Trust on a taxable basis, and on the termination of the Distributing ROI Funds, unitholders of the Distributing ROI Funds will receive units of the Trust pro rata based on the relative net asset values of the Distributing ROI Funds. "The Trust benefits from a flexible structure: it is not restricted or limited by the SIFT Legislation that applies to REITs, nor is it required to comply with the regulations governing mortgage investment corporations."

See full summary under Mergers & Acquisitions – REIT/Income Fund/LP Acquisitions – Taxable Trust Mergers.

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Tax Topics - Public Transactions - Mergers & Acquisitions - REIT/Income Fund/LP Acquisitions - Taxable Trust Mergers Merger of ROI Canadian High Income Mortgage Fund, ROI Canadian Mortgage Income Fund and ROI Canadian Real Estate Fund into Dream Hard Asset Alternative Trust and termination of their forward/mirror fund structure 1477