Category Archives: Advanced ACB Topics

Tax Treatment of the TC Energy / South Bow Spin-Off

TC Energy Corporation (TSX: TRP) completed a spin-off of South Bow Corporation (TSX: SOBO) on the record date of October 1, 2024.  TC Energy shareholders received 0.2 shares of South Bow for each shares of TC Energy held on the record date. TC Energy published a Management Information Circular document highlighting the tax treatment of […]

Tax Treatment of the Brookfield Renewable Partners LP Unit Split and Creation of Brookfield Renewable Corporation (BEPC)

On July 30, 2020 Brookfield Renewable Partners L.P. (BEP.UN) completed a unit split corporate event resulting in each unitholder of BEP.UN on record as of July 27, 2020 receiving 0.25 shares of Brookfield Renewable Corporation (BEPC) for every unit of BEP.UN.  In addition, a cash payment was made in lieu of fractional shares. https://bep.brookfield.com/press-releases/2020/07-16-2020-220045986 On […]

Tax Consequences of the Power Financial Corporation – PFC (PWF.TO) / Power Corporation of Canada – PCC (POW.TO) Reorganization

Power Corporation and Power Financial announced the completion of a reorganization and share exchange on February 13, 2020: https://www.powerfinancial.com/en/news/press-releases/2020/power-corporation-and-power-financial-announce-completion-of-reorganization-and-the-determination-of-the-final-offer-price-for-the-pre-emptive-right-122598/ Power Corporation of Canada (“Power Corporation” or “PCC”) (TSX: POW) and Power Financial Corporation (“Power Financial” or “PFC”) (TSX: PWF) today announced the successful completion of the previously announced reorganization transaction (the “Reorganization”) pursuant to which, […]

Tax Treatment of the Brookfield Infrastructure LP Unit Split and Creation of Brookfield Infrastructure Corporation (BIPC)

On March 31, 2020 Brookfield Infrastructure Partners L.P. (BIP.UN) announced the completion of a unit split corporate event resulting in each unitholder of BIP.UN on record as of March 20, 2020 receiving 1 shares of Brookfield Infrastructure Corporation (BIPC) for every 9 units of BIP.UN.  In addition, a cash payment was made in lieu of […]

Enbridge Income Fund Holdings (ENF) Acquisition by Enbridge (ENB): Implications for Adjusted Cost Base

In 2018 Enbridge Inc. (ENB) completed its plan to acquire all outstanding shares of Enbridge Income Fund Holdings Inc. (ENF).  Under the arrangement, ENF shareholders received: 0.7350 shares of ENB, and a cash payment of $0.45 for each share of ENF held on November 15, 2018.  An ENF shareholder also received an accrued ENF dividend […]