Conversion to Parkland Fuel Corporation
Specified Investment Flow-Through ("SIFT") rules, originally announced by the Canadian Federal Government on October 31, 2006, introduced a tax on distributions paid by publicly traded trusts and partnerships that were created on or after October 31, 2006. Publicly traded trusts and partnerships that were created prior to this date were granted a grace period so that the SIFT tax would not apply until 2011 as long these entities complied with specific growth guidelines, as set out in a December 15, 2006 Department of Finance press release.
Parkland management subsequently determined that, at the conclusion of the grace period, it would be more tax efficient for Parkland and its shareholders to convert to a corporation. Parkland converted to a corporation by way of a trust unit for corporate share tax-deferred exchange on December 31, 2010.
Parkland Fuel Corporation's shares and debentures commenced trading effective at the opening on Friday, January 7, 2011. At this time, Parkland’s common shares, 6.5% series 1 convertible unsecured subordinated debentures and 5.75% series 2 convertible unsecured subordinated debentures started trading on the TSX under the symbols "PKI", "PKI.DB" and “PKI.DB.A”, respectively
||70137T 10 5
|6.5% Convertible Unsecured Subordinated Debentures
||70137T AA 3
|5.75% Convertible Unsecured Subordinated Debentures
||70137T AB 1
Eligible Unitholders who wish to make a joint tax election with New Parkland under section 85 of the Tax Act may require the fair market value of Class B and C Units on December 31st, 2010 to make such an election. The value of Class B and C limited Partnership units at close of trading on December 31st, 2010 was $11.49 per unit, equal to Parkland Income Fund's Trust unit price at close of business that same day.