2007 Ruling 2007-0224201R3 - Unit trust - Capital gain allocation -- summary under Subsection 104(7.1)

Trust agreements are amended to provide that the trustee shall allocate all or a portion of net capital gains realized by the trust in the year to unitholders who have redeemed units of the trust at any time in the year, provided that the amount of net capital gain so allocated to a particular redeeming unitholder shall not exceed the amount by which the amount payable on the redemption of the units exceeds the adjusted cost base of the units being redeemed, and to provide that proceeds of redemption otherwise payable will be reduced by the amount of such allocation: ruling that s. 107(4.1) will not apply.