2023 Ruling 2022-0958681R3 - Conversion to open-end unit trust -- summary under Disposition

CRA ruled that the conversion of a listed REIT from a a closed-end unit trust under s. 108(2)(b) to an open-end unit trust under s. 108(2)(a) through the addition of a retraction right to the unit terms would accomplish that objective and would not result in a dispostion of trust property or of units. The ruling letter specified a requirement that the term of any notes issued and transferred to a retracted unitholder would not have a term of greater than X years from the date of issue.