Current market conditions and Canadian tax changes have depressed trading prices of Canadian income funds. Nevertheless, many such funds own businesses that are attractive targets for foreign strategic buyers looking to make longer-term investments. In acquiring the business of a Canadian income fund, a foreign buyer must, however, understand the structure through which the fund owns the business. Such structures are tax driven, and tax considerations and opportunities are key to getting the deal done.

type Tax Law Bulletin - December 2008 - Canadian Income Funds: Prospective Targets for Foreign Investment