Category Archives: Advanced ACB Topics

Taxation of the A&W Revenue Royalties Income Fund / A&W Food Services of Canada Inc. Reorganization

On October 17, 2024 A&W Revenue Royalties Income Fund (symbol: AW-UN.TO) and A&W Food Services of Canada Inc. (symbol: AW.TO) completed a reorganization, resulting in A&W Revenue Royalties Income Fund units being exchanged for a combination of cash and shares of A&W Food Services of Canada Inc.. Prior to reorganization, AW-UN.TO unitholders could elect to […]

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 […]