Subsection 132.2(1) - Definitions re qualifying exchange of mutual funds
Qualifying Exchange
Administrative Policy
2017 Ruling 2016-0660321R3 - Reorg of REIT to simplify multi-tier structure
Background
Fund, which is a REIT under s. 122.1, holds notes and all the units of a unit trust (“Sub-Trust”). Sub-Trust owns the Class A LP...
| 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 transfer of sub-trust’s assets to sister MFT trust | 459 |
| 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 | 146 |
| 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) | 325 |
| 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 | 165 |
| 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 | 245 |
2013 Ruling 2013-0492731R3 - qualifying disposition -mutual fund trust
The elimination of the subtrust of an open-end listed mutual fund trust (the "Fund") was to be accomplished by the subtrust transferring its...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(1) | elimination of REIT sub trust through s. 107.4 transfer to new "in house" MFT and s. 132.2 merger of MFT into REIT | 644 |
| Tax Topics - Income Tax Act - Section 132 - Subsection 132(6) | MFT's trustee not to be a director of a sub | 119 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | no disposition on MFT units consolidation back to the previous number, occurring outside a Plan of Arrangement | 107 |
2013 Ruling 2013-0488351R3 - Conversion of a MFC to a MFT
The same (mutual fund corporation) taxpayer as for 2013 Ruling 2011-0395091R3 ("MFC to MFT Conversion") (immediately below) obtained essentially...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(1) | conversion of MFC to MFT and subtrust elimination | 180 |
| Tax Topics - Income Tax Act - Section 21 - Subsection 21(1) | election of GP to capitalize loss before elimination of subtrust | 204 |
2013 Ruling 2011-0395091R3 - MFC to MFT Conversion
Background
Taxpayer, which is a listed mutual fund corporation, wishes to convert to a mutual fund trust (so that following the conversions...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(1) | 210 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | deductible interest on internal assumption (no release) | 159 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (f) | 177 |
5 May 1995 External T.I. 9511935 - NEWLY ESTABLISHED FUND
Where a mutual fund corporation transfers its assets to a newly established unit trust that will not meet the distribution requirements under...
Articles
Hugh Chasmar, "Corporate Class Funds", Canadian Tax Highlights, Vol. 25, No. 8, August 2017, p. 6
Expansion of s. 132.2 to permit division of multi-class MFC into multiple MFTs (p. 7)
[Under] proposed section 132.2…a multi-class MFC with 20...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 131 - Subsection 131(4.1) | 258 |
Subsection 132.2(3) - General
Paragraph 132.2(3)(a)
Articles
Darcy De Moche, Greg Johnson, "Recent Developments and Transactions Affecting Income Funds and Royalty Trusts", 2005 Conference Report, c. 17.
Forms
T1169 "Election On Disposition Of Property By A Mutual Fund Corporation (Or A Mutual Fund Trust) To A Mutual Fund Trust
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)
Administrative Policy
2017 Ruling 2016-0660321R3 - Reorg of REIT to simplify multi-tier structure
Background
As a result of quite a number of other transactions, a REIT (the “Fund”) holds the Class A LP Units of the Partnership (as well as...
| 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 | 1006 |
| Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(2) - Paragraph 107.4(2)(a) | s. 107.4 transfer of sub-trust’s assets to sister MFT trust | 459 |
| 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 | 146 |
| 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) | 325 |
| 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 | 165 |