Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations — (a)
specified transaction means (a) in relation to an attribution point in respect of a non-stratified investment plan for a taxation year of the investment plan, the acquisition of units of the investment plan by a person, or by a group of persons, from the investment plan if (i) the acquisition by the person, or each acquisition by a member of the group of persons, occurs less than 31 days before the attribution point, (ii) the units are disposed of, within the meaning of subsection 248(1) of the Income Tax Act , by the person, or by each member of the group of persons, within 30 days after the attribution point, (iii) in the case of the acquisition of the units by a group of persons, each member of the group is related to every other member of the group, (iv) the total value of the units as of the attribution point is greater than the lesser of (A) $10,000,000, and (B) 10% of the total value of all of the units of the investment plan on the attribution point, (v) the investment plan’s percentage for any participating province and for the taxation year, determined without reference to subsection 32(3), is less than the amount that would be that percentage if that percentage were determined without reference to the units, and (vi) the acquisition by the person, or any acquisition by a member of the group of persons, does not meet one or more of the following conditions: (A) the acquisition is undertaken by the person or member and the investment plan in good faith as part of the normal business practice of the investment plan, (B) the person or member and the investment plan deal with each other at arm’s length, (C) the acquisition is made for consideration equal to or greater than the total value of the units at the time of the acquisition, (D) neither the investment plan nor the manager of the investment plan provide any guarantees or indemnities to the person or member with respect to gains or losses in the value of the units during the period beginning on the particular day the acquisition occurred and ending on the day that is 30 days after the particular day, and (E) any fees charged by the investment plan to the person or member in respect of the units are similar to fees charged by the investment plan to other persons holding units of the investment plan; and (b) in relation to an attribution point in respect of a series of a stratified investment plan for a taxation year of the investment plan, the acquisition of units of the series by a person, or by a group of persons, from the investment plan if (i) the acquisition by the person, or each acquisition by a member of the group of persons, occurs less than 31 days before the attribution point, (ii) the units are disposed of, within the meaning of subsection 248(1) of the Income Tax Act , by the person, or by each member of the group of persons, within 30 days after the attribution point, (iii) in the case of the acquisition of the units by a group of persons, each member of the group is related to every other member of the group, (iv) the total value of the units as of the attribution point is greater than the lesser of (A) $10,000,000, and (B) 10% of the total value of all of the units of the series on the attribution point, (v) the investment plan’s percentage for the series, for any participating province and for the taxation year, determined without reference to subsection 30(3), is less than the amount that would be that percentage if that percentage were determined without reference to the units, and (vi) the acquisition by the person, or any acquisition by a member of the group of persons, does not meet one or more of the following conditions: (A) the acquisition is undertaken by the person or member and the investment plan in good faith as part of the normal business practice of the investment plan, (B) the person or member and the investment plan deal with each other at arm’s length, (C) the acquisition is made for consideration equal to or greater than the total