Plan of Arrangements - rollover vs no rollover options

Tax Topics
1

Hello, hope someone can confirm my understanding of these Brookfield Property (BPY.UN) plan of arrangement options.
The shares are held in an RRSP account.
There is an option for rollover treatment and no rollover treatment:

Option 3: Shares (BAM Shares) (Canadian Shareholders Only)(Rollover Treatment)
To receive 0.4006 Class A Limited Voting Shares in the capital of BAM per deposited unit of
Brookfield Properties Partners LP Units.

Option 4: Shares (BAM Share) (No Rollover Treatment)
To receive 0.4006 Class A Limited Voting Shares in the capital of BAM per deposited units of
Brookfield Properties Partners LP Units.

My understanding of rollover treatment means that tax on any capital gains upon receipt of BAM.A shares in exchange for BPY.UN shares will be deferred until BAM.A shares are disposed.
The rollover would also require filing a joint tax election, which is also mentioned in the plan of arrangement.
Since the BPY.UN shares are held in a registered account, there is no advantage to selecting rollover treatment, and option 4 is the most applicable of the 2.

Is my understanding correct? I want to be sure I haven’t missed any tax implications for option 4, like capital gains being treated as an RRSP contribution.

Thanks

2

I’m not familiar with this arrangement but generally, yes, the capital gain will be deferred until the replacement shares are sold in a share-for-share arrangement. Normally the election (under ss 85(1)) will be used to defer the gains. However, where the shares are held in an RRSP, there shouldn’t be any concern about realizing the gains. There is no tax on the gain. The annuitant is taxed on the value removed from the RRSP someday. A roll-over or deferral is of no benefit within the RRSP.

3

Appreciate the response. That confirms what I thought. In this case, both options 3 and 4 seems to be the same in an RRSP, so I’ll assume that option 4 is the more “appropriate” way to exchange the BPY.UN shares for BAM shares.