Foreign investments in and acquisitions of publicly-traded Canadian flow-through entities : impact of recent controversies and proposed changes

This article considers the implications of controversial proposed tax changes in Canada for foreign investors in, or foreign acquirers of, Canadian businesses carried on through publicly-traded flow-through trusts. These proposals would terminate flow-through tax treatment and substitute tax effects comparable to those historically applicable to publicly-traded taxable Canadian corporations. The issues are examined in the context of a comparative review of Canada's tax treatment of foreign investors in, or foreign acquirers of, publicly-traded Canadian corporations.