Examples of SIFT Regime in a sentence
Subject to the application of the SIFT Regime (as defined herein) discussed under the heading "Certain Canadian Federal Income Tax Considerations", returns on capital are generally taxed as ordinary income, capital gains or dividends in the hands of a Unitholder while returns of capital are generally tax-deferred (and reduce the Unitholder's cost base in the Unit for tax purposes).
Application of the SIFT Regime may, depending on the nature of distributions from the REIT, including what portion of its distributions is income and what portion is a return of capital, have a material adverse effect on the after-tax returns of certain Unitholders.
There can be no assurances, however, that the REIT will be able to restructure such that it will not be subject to the tax imposed by the SIFT Regime, or that any such restructuring, if implemented, would not result in material costs or other adverse consequences to the REIT and the Unitholders.
Management of the REIT has informed counsel that the REIT intends to take such steps as are necessary to ensure that, to the extent possible, it qualifies for the REIT Exception and any negative effects of the SIFT Regime on the REIT and the Unitholders are minimized.
Management of the REIT believes that any impact of the SIFT Regime on Unitholders would be significantly mitigated in 2015 due to the large proportion of the distributions which are expected to be made by way of return of capital.
This includes requirements that Crombie qualifies as a "mutual fund trust" as defined in the Tax Act, and ensuring that the SIFT Regime (as described in more detail below) under the Tax Act is not applicable to Crombie.The following summary of these rules is of a general nature only and is based upon the current provisions of the Tax Act and the Regulations, and all proposals to amend the Tax Act and the Regulations publicly announced by the Minister of Finance (Canada) prior to the date hereof.
Subject to the application of the SIFT Regime (as defined herein) discussed under the heading "Certain Canadian Federal Income Tax Considerations", returns on capital are generally taxed as ordinary income, capital gains or dividends in the hands of a Unitholder while returns of capital are generally tax-deferred (and reduce the Unitholder's tax cost in the Unit for tax purposes).
Management of the REIT believes that any impact of the SIFT Regime on Unitholders would be significantly mitigated in 2020 due to the large proportion of the distributions which are expected to be made by way of return of capital.
The application of the SIFT Regime to the REIT would not change the treatment under the Tax Act of distributions in a year that are in excess of the REIT’s net income for the year.
Management of the REIT believes that any impact of the SIFT Regime on Unitholders would be significantly mitigated in 2019 due to the large proportion of the distributions which are expected to be made by way of return of capital.