The Declaration of Trust of a Canadian REIT (the “Fund”) will be amended to provide for the consolidations of its units following s. 132.2 merger transactions, for the in specie redemption of Fund units through distribution of securities of a Fund subsidiary including units of a mutual fund trust received in connection with one of such s. 132.2 merger transactions and adding the right of a subsidiary to renounce its right for most of the Fund Units otherwise issuable on one of the s. 132.2 merger transactions.
An indirect subsidiary of the Fund (Opco) and a newly-incorporated subsidiary of Opco (GP II) will form Opco Partnership as a general partnership, with Opco transferring real estate to Opco Partnership on a s. 97(2) rollover basis. Opco Partnership will then be converted to a limited partnership, with no significant changes to the rights and obligations of the partners other than Opco becoming a limited partner.
Rulings that neither transactions result in a disposition.