2007 Ruling 2007-0245281R3 - windup of income trust on sale of assets:3rd party -- summary under Subsection 104(6)

After the acquisition of a mutual fund trust (the "Fund") by Bidco, the Fund sells all its assets, including an interest in a limited partnership, to Bidco in consideration for the assumption of liabilities and a note of Bidco. The Fund then declares a distribution of the capital gain realized by it on such sale, and also declares a distribution of other taxable income and of a capital distribution, and satisfies the distributions by distributing the note to Bidco. Ruling that the Fund will receive a s. 104(6) deduction for the amount of income that is so distributed by it.