In our M&A Outlook for 2012, we discussed the
emergence, in 2011, of foreign asset income trusts and noted that
we expected the trend to continue in 2012 with offerings providing
Canadian yield-seeking investors with exposure to foreign-based
real estate assets. In fact, in 2012, a number of offerings were
brought to market providing Canadian investors with exposure to
various classes of real estate assets from multi-unit residential
to industrial. With the search for yield still very prominent, look
for more of such offerings in 2013.
Structures used by non-residents of Canada for acquiring shares
of Canadian corporations and Canadian assets will likely see some
revisions in 2013. Currently, the Canadian tax system provides a
competitive advantage to non-resident bidders for shares of
Canadian corporations and other Canadian based assets over their
Canadian resident counterparts. Generally, non-residents are able
to use internal leverage to reduce the future taxes
