Clause 27 relates to the “allocations to redeemers” measure, which relates to certain mutual fund trusts. Over the last several years, the mutual fund trust industry has developed a methodology for avoiding double taxation whereby they have redeeming unitholders. Some planning had evolved in order to achieve tax deferrals or recharacterization benefits through the use of this methodology, so this measure would prevent the use of this “allocations to redeemers” methodology, which was intended to prevent double tax, from providing tax benefits.
On May 27th, 2021. See this statement in context.