2007 Ruling 2007-0245281R3 - windup of income trust on sale of assets:3rd party -- summary under Subparagraph 53(2)(h)(i.1)

This contemplated the winding-up of an income fund (the "Fund") following its acquisition by a "Bidco" in which the Fund sold its assets (mostly an LP interest) for a Bidco note, distributed that note to Bidco in satisfaction of a capital distribution and capital gains distribution declared by the Fund trustees and then redeemed its units for nominal proceeds. Ruling that the amount of the net capital gains allocation that was (separately) paid to the unitholder did not reduce the ACB of its units.