I would be happy to do so. Thank you.
I'm sorry. I'm trying to balance going quickly with providing a full explanation, and it is a complex measure.
A mutual fund trust is a trust with a number of unitholders, and those unitholders can achieve liquidity, which is to say sell their investment or change their investment for cash, either through selling their units in the market or through a redemption of their units. They can tell the mutual fund trust that they'd like to redeem some of their units that currently have a net asset of x dollars and they can redeem them for that.
When a unitholder redeems their units of a trust, they can be taxable on a gain themselves, based upon their disposition of their trust units, and then the mutual fund trust itself will have to sell off some of its investments in order to refund their redemption, so they can have capital gains or ordinary income triggered in the mutual fund. The allocation-to-redeemers methodology is used in order to allocate some of the gains realized by these trusts in order to fund redemptions out to the unitholders, to avoid double tax so that the trust and the unitholder aren't taxed in the same economic vein.
Where the tax planning occurs is that some of the trusts were allocating more than was required to fund the redemption, which, through the specific mechanism of the tax rules, would provide a deferral benefit in certain cases, and also provide for ordinary income in the trust to be effectively taxed at a capital gains rate for redeeming unitholders. This measure would ensure that the methodology can be used to prevent double tax, so that when I redeem some of my units of my investment fund, there are not two incidents of tax on it, but it would prevent some of the tax benefits that have developed.