The Resource Canadian syndication of foreign income-producing real estate

Canadian syndication of foreign income-producing real estate

Label
Canadian syndication of foreign income-producing real estate
Title
Canadian syndication of foreign income-producing real estate
Creator
Subject
Language
eng
Summary
This article provides a précis of business and other considerations that may be relevant to an existing portfolio owner that is considering an offering in Canada; a general background on how Canadian income funds work; a very brief contextual synopsis of Canadian rules that tax some publicly traded trusts and partnerships and why foreign-sourced business and other income is not subject to their application; and a summary of four cross-border or foreign income fund structures that may be employed in a number of scenarios in order to minimize the incidence of both domestic and foreign entity-level taxation. The four structures discussed in this article are: internally leveraged Canadian income trust - uses debt internally so as to minimize entity-level taxation without the need to qualify the business as a real estate investment trust for U.S. tax purposes without triggering an inversion in the U.S.; limited partnership investing in U.S. REIT - uses a flow-through Canadian limited partnership that invests in a U.S. entity that is intended to qualify as a REIT for U.S. tax purposes without triggering an inversion in the U.S.; dual Canadian income trust/U.S. REIT structure - uses a flow-through Canadian income trust that is intended to simultaneously qualify as a REIT for U.S. tax purposes by triggering an inversion in the U.S.; and non-U.S. leveraged income fund - uses debt internally so as to minimize entity-level taxation for non-Canadian and non-U.S. properties
Citation source
In: Tax notes international. - Falls Church. - Vol. 70 (2013),
http://library.link/vocab/creatorName
  • Bernstein, J
  • Gucciardo, F
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • foreign source income
  • immovable property
  • foreign investment fund
  • REIT
Label
Canadian syndication of foreign income-producing real estate
Instantiates
Publication
Label
Canadian syndication of foreign income-producing real estate
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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