Here's something from Barron's that gives more color.... Also, if you are interested, check out Bill Cara here http://www.billcara.com/archives/2006/08/about_those_cdn.html
UP AND DOWN WALL STREET DAILY | By RANDALL W. FORSYTH
The new tax treatment wouldn't take effect until 2011, however, and wouldn't even hit Canadian investors, explains Robert Willens, Lehman Brothers' tax expert. "For Canadians, it's irrelevant." Canadian investors can "impute" taxes paid by corporations, effectively getting around the double taxation of dividends, which the "primitive" U.S. tax system doesn't allow, he adds. As part of tax change, the Canadian corporate tax rate also will be lowered to 18.5%.
The only beneficiaries of the current royalty-trust structure are tax-exempt investors, such as retirement funds and endowments, and non-residents. "It's all about U.S. investors," Willens says of the proposed tax change, which he says will likely gain passage because it was proposed by the supposedly business-friendly Conservative government.
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So throw out my due process comment. But...it seems like the rest holds reasonably well.
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