A handy Foreigners' takeover guide for income trusts from the friendly folks at

Guide: Acquisitions of Canadian Income Trusts
February 2, 2010

Practice Area(s):
Mergers & Acquisitions

Davies Ward Phillips & Vineberg

The income trust phenomenon has been a uniquely Canadian experience. Starting in the late 1990s, these publicly-traded unit trusts expanded rapidly beyond their traditional sphere of oil and gas royalty investments and came to dominate the Canadian public real estate market, as well as to occupy a central position in the Canadian capital markets for virtually all business sectors. Their structure as flow-through entities has provided significant tax benefits and enabled a high level of distributions to investors.

However, as a result of Canadian income tax changes first announced in 2006, most income trusts (other than certain real estate investment trusts) will become subject to entity-level taxation on January 1, 2011, and the traditional tax benefits of conducting business through a Canadian income trust structure will be eliminated.

2010 will be a critical year for Canadian income trusts. The looming tax deadline is likely to see an increased interest in acquisitions of income trusts, primarily on the part of investors who have adequate access to capital to fund such acquisitions. This Guide is intended to provide potential acquirors and other interested parties with a summary of the principal legal and regulatory considerations relevant to such acquisitions.


Acquisitions of Canadian Income Trusts. See more here:
 
Buy one today! No 31.5% tax for foreigners or pension funds, just schmuck Canadians!
 
This Guide is intended to provide potential acquirors and other interested parties with a summary of the principal legal and regulatory considerations relevant to such acquisitions. See more here:
 
Flaherty wrote the rules so foreigners could evade taxes by reducing withholding tax on foreign held debt to ZERO!