2017 Ruling 2016-0625301R3 - Merger of two related segregated fund trusts -- summary under Paragraph 138.1(1)(a)

CRA ruled that the s. 107.4 rollover applied to the “transfer” of all the property of one segregated fund to another segregated fund held by the same insurer. The insurer was the legal and beneficial owner of both funds’ properties (in each case, consisting of units of a mutual fund trust) both before and after, so that the transfer consisted in the insurer starting to book the securities of the first fund as being securities of the second fund, and adjusting the notional units of the policyholders accordingly. Thus, such reallocations of the MFT units was sufficient to effect their transfer of property from one fund (which was deemed by s. 138.1 to be a trust) to the second such deemed trust.